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Resource Conservation and Recovery Act “RCRA” November 18, 1980

Resource Conservation and Recovery Act “RCRA” November 18, 1980. Public Acts. 1976 Resource Conservation & Recovery Act Required permits for hazardous waste facilities that disposed or burned waste Prohibited opened dumping without permit Authorize funding to study waste issues

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Resource Conservation and Recovery Act “RCRA” November 18, 1980

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  1. Resource Conservation and Recovery Act “RCRA” November 18, 1980
  2. Public Acts 1976 Resource Conservation & Recovery Act Required permits for hazardous waste facilities that disposed or burned waste Prohibited opened dumping without permit Authorize funding to study waste issues Not an enforcement program 1980 Resource Conservation & Recovery Act Current Hazardous Waste laws Includes enforcement
  3. “Title 40 of the Code of Federal Regulations, Parts 260-280(40 CFR 260-280) Part 260 & 261 Defines solid and hazardous waste Conditionally exempt SQG requirements Part 262 LQG and SQG quantity generator requirements Part 263 Transporter requirements Part 264, 265, 270 Permit requirements (TSDF) Some LQG and SQG requirements Part 266 Recyclable materials requirements Used in a manner constituting disposal Precious metals Lead-acid battery reclamation Industrial boilers and furnaces Military munitions Part 268 land disposal restrictions Part 271 and 271 state authorization list of authorized states (CT is subpart H) Part 273 universal waste rule Part 279 used oil rule Part 280 underground storage tanks
  4. The Regulations Cradle to Grave Preventative law
  5. Love Canal, Niagara NY 15 acres with 60ft by 3000ft canal along Niagara River 1920, purchased by Hooker Chemical 1920 – 1953, used as a landfill by city and manufacturers. 1953, sold to the city’s board of education ($1.00) Deed stated not to dig within the area of the canal 1954, Board of Ed. built schools and housing (1000) Disregarded warning on deed Chemicals seeped into basements and storm drains Drums popping up in ball fields and yards Residents started complaining 1978, years of residents complaints forced evacuation of several city blocks 2010, a few city blocks still restricted
  6. Times Beach, MI Russell Bliss, waste oil company 1960s - 1970s collected waste from area businesses Claimed that only waste oil was collected Later determined other toxic waste mixed with oil Oil used for dust control on roads and stables 1971 – 1972, Sixty two horse die at area stables. 1972 – 1976, Times Beach hires Russell Bliss to oil roads 1977, EPA begins investigation into horse deaths Some waste came from NE Pharmaceutical and Chemical Corp 2,4,5T and 2,4D (agent orange) Contains dioxin PCBs also found 1983, EPA purchases the town and evacuates residents constructed an on-site incinerator & incinerate 26,000 tons of contaminated soil Current – Town park (still polluted)
  7. Valley of the Drums, Brooks KY 13 acre gravel pit owned by A. L. Taylor 1967 – 1977, took in over 38,000 drums of waste from area paint and coating manufacturers 11,000 drums buried and/or burned 27,000 drums stored on the ground 1979, EPA begins cleanup Cleanup continues to this day
  8. The Law Penalties Civil (violation of the regulations) $25,00.00/day/violation “waste determinations” – most common violation Criminal (knowing your violating) Penalties ($50,000.00/day/violation) Prison – 5 years in CT
  9. Civil Penalties Home Depot (9 stores) $425,000.00 & company wide compliance program in CT Over 40,000 pounds 2,4-D Light Sources, Milford & Orange $857,000.00 & clean up mercury releases Polluted both properties with mercury
  10. Criminal Penalties Sound Mfg, Norwich (Taftville) 3 years, $100,000 fine & $1,000,000 cash bond for clean up Buried 50,000 pounds lead paint sandblasting waste Phoenix Products, Plymouth 3 years probation $250,000 1500-gallons waste acid to sewer
  11. Who is Regulated Any business that – Generates hazardous waste, used oil, universal waste Transports hazardous waste, used oil, universal waste Stores, treats, disposes of hazardous waste, used oil, universal waste Must apply for an EPA Id. No. Address specific (not by business name) Denotes expected generator category Home owners (and tenants) and home owner derived waste is excluded
  12. Who are the HW Generators Retail establishments pharmacies photo shops hardware stores garden centers big & small box retailers Public service sector hospitals & clinics prisons schools state parks town garage power plants gun clubs navy coast guard air national guard army national guard atomic energy lab Service sector auto body ship/boat repair electroplating lead abatement bridge painting vehicle repair furniture repair auto recyclers printers machine shop/metal forming dry cleaners scrap metal exterminators tank truck washing waste recyclers Manufacturing ship & boat aircraft ball bearings lighters fluorescent lamps hardware tools guns paint & coatings chemicals lamp posts circuit boards electronic equipment laminated fabrics /paper bakeries extruded aluminum structures foundry glass products asphalt shoe inserts wire guitars racing engines surgical thread space suits batteries cabinets filter elements furniture glides cosmetic containers explosives ant traps pharmaceuticals galvanized guard rails metal boxes buckles Styrofoam
  13. Generator Categories Treatment, storage, disposal facilities (TSDF) Can also be LQG, SQG, CESQG Large quantity generator (LQG) Greater than 1000 kilograms (or greater than 1 kilogram acute waste) per month Small quantity generators (SQG) 100 to 1000 kilograms (or 1 kilogram acute waste) per month Conditionally exempt small quantity generators (CESQG) Less than 100 kilograms (or less than 1 kilogram acute waste) per month LQG, SQG, CESQG is based on a month to month determination. Can be CESQG one month and LQG the next depending on amount of waste generated and/or stored on-site during each respective month
  14. Generator Categories Waste transporters Permit exempt reclamation/recycling Lead-acid batteries, precious metals, industrial boilers, recyclers (no storage, burning, disposal) Used oil handlers, burners, blenders Universal waste handlers
  15. Treatment Storage Disposal Facilities (TSDF) RCRA Part B Permit EPA Id. No. (example CTD116502534) Type and volume of waste on-site Storage, treatment, and handling methods Waste tracking and analysis Secondary containment systems Emission controls (VOCs) Employee training Job descriptions Weekly/daily inspections and logs Emergency response plan Shipping records Annual reporting Closure plan and cost estimate Financial assurance and insurance Groundwater monitoring (land disposal units) Site wide corrective action
  16. Large Quantity Generator (LQG) Greater than 1000 kilograms/month or at any one time (5 drums) Greater than 1 kilogram acute HW (1 quart) 90-day storage limit Exceed 90-days – considered TSDF without permit Substantial management requirements EPA Id. No. (example CTD000502534) Determining if waste is HW Secondary containment/impervious base Weekly/daily inspections and logs Employee training Job descriptions Emergency response plan Emission controls (VOCs) Shipping records Biennial reporting
  17. Small Quantity Generator (SQG) 100 to 1000 kilograms/month Never exceed 1000 kilograms at any one time Never exceed l kilogram acute HW 180-day storage limit (270 days if over 200 miles) Exceed any above – considered TSDF without permit Less substantial management requirements EPA Id. No. (example CTD000502534) Determine if waste is HW HW manifests Weekly/daily inspections and logs Secondary containment/impervious base No open top tanks Employee training (no records required) Posting emergency information near phone
  18. Conditionally Exempt Small Quantity Generator (CESQG) Less than 100 kilograms/month Less than 1 kilogram acute HW Never exceed 1000 kilograms (or 1 kilogram acute waste) at any one time Exceed 1000 kilograms (or 1 kilogram of acute waste) – considered LQG Even less substantial management requirements Determine if waste is HW Don’t dispose of HW in CT solid waste facilities (LF, CRRA, etc) Can use household hazardous waste collection

  19. TSDF In CT

    Three active commercial TSDF Storage & treatment Six inactive commercial TSDF Disposal, storage & treatment Six active non-commercial TSDF Storage & treatment Dozens inactive non-commercial TSDF Disposal, storage & treatment Waste piles Landfills Surface impoundments Injection wells Treatment processes Tank & container storage
  20. Generators in CT LQG 300 SQG 1700 CESQG unknown (don’t have to get EPA Id. No.) Other “state” permitted facilities Treating contaminated soil (on & off-site) Blend used oil fuel Recover precious metals from HW Lead-acid battery recycling Used electronics recycling Fluorescent lamp recycling Bio diesel (from waste vegetable/animal oil)
  21. Questions/Comments
  22. Where it Begins Determine if your waste is a solid waste Solid wastes are – Spent material Sludge By-product Commercial chemical product Scrap metal when discarded by – Burned (energy recovery) Recycled/reclaimed Accumulated speculatively Used in a manner constituting disposal* *placed on land or water or incinerated
  23. Couple of exclusions to the definition of solid waste Waste fuel reused as a fuel Water/gas mixtures sent for fuel blending Waste is effective substitute for a commercial chemical product, provided the product is not used in a manner constituting disposal or burned. Spent plastic bead blast media (paint removal) Used in water resistant concrete block (Sealtech block) Applied above ground – not solid waste Applied on the ground – is solid waste Fly ash used to make zinc powder (Exeter Energy) Used in galvanizing – not solid waste (US Zinc) Used in plant food – is solid waste (Bay Zinc)
  24. The Hazardous Wastes A solid waste that is: LISTED AS HAZARDOUS WASTE (Part 261.31 – 33) and/or EXHIBITS A CHARACTERISTIC OF HAZARDOUS WASTE (Part 261.21 – 24)
  25. And 2 sub-categories………… “Used Oil” (part 279) and “Universal Waste” (part 273)

  26. Couple of exclusions from the definition of hazardous waste

    “lobbyist exclusions” Drilling fluids from oil and gas production heavy metals, volatile organic compounds, corrosives Cabot Oil, 2009, water supply well explode, 14 water supplies polluted Fly & bottom ash from burning coal or fossil fuel heavy metals and volatile organic compounds TVA Kingston Plant, 2008, 1,000,000-gallon coal ash slurry release Waste from extraction/processing of ore heavy metals and volatile organic compounds Asarco mine & ore sites (11 mid west) waste piles with heavy metals & radioactive materials
  27. Waste Codes Hazardous wastes are identified by “waste codes” (except for used oil and universal waste) The listed waste codes F, K, U, P (Example – F006 metal hydroxide sludge from electroplating) The characteristic waste codes D waste codes (Example – D001 ignitable)
  28. Reason for Waste Codes National statistical information Observe trends in waste generation Pollution prevention programs Eliminate/reduce large volume waste types Hazard recognition Waste codes represent specific hazards
  29. “LISTED HAZARDOUS WASTE” THREE TYPES: NON-SPECIFIC SOURCE “F” waste codes (40 CFR 261.31) SPECIFIC SOURCE “K” waste codes (40 CFR 261.32) COMMERCIAL CHEMICAL PRODUCTS U & P waste codes (40 CFR 261.33)
  30. SOME FACTS ABOUT LISTED HAZARDOUS WASTE Reasons for Listing Ignitable (I) Corrosive (C) Reactive (R) Acutely Hazardous (H) Toxic (T)
  31. SOME FACTS ABOUT LISTED HAZARDOUS WASTE Mixture Rule mixing a listed waste with any other solid waste makes the entire mixture a listed waste! not dependent on amount (one drop, one gallon, etc). not dependent on the source (intentional mixing, accidental mixing). Can cause an otherwise inexpensive waste to become more expensive when shipped off-site
  32. Listed Hazardous Waste“Non-Specific Source”“F” Waste Codes(261.31) Waste from generic sources: F001 – F039 Solvents (F001 – F005) Metal finishing (F006 – F019) Pesticides/wood preservative [dioxin] (F020 - F035)
  33. Common “F” Waste in CT F001 (T) F002 (T) The following spent halogenated solvents used in degreasing: tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1 trichloroethane, carbon tetrachloride, chlorinated fluorocarbons, still bottoms from solvent recovery The following spent halogenated solvents: tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1 trichloroethane, carbon tetrachloride, chlorinated fluorocarbons, still bottoms from solvent recovery
  34. HALOGENS Chemical with the word chloro or fluoroin its name Perchloroethylene (1.6) Trichloroethylene (1.46) methylene chloride (1.33) “HEAVIER THAN WATER” IMPROPER TREATMENT = DIOXINS
  35. F003 (I) F005 (I,T) The following spent non-halogenated solvents: xylene, acetone, ethyl acetate, ethyl benzene, ethyl ether, methyl isobutyl ketone, butyl alcohol, cyclohexanone, methanol, still bottoms from solvent recovery. The following spent non-halogenated solvents: toluene, methyl ethyl ketone, carbon disulfide, isobutanol, pyridine, benzene, 2-ethoxyethanol, 2-nitropropane ; still bottoms from recovery of spent solvents Common “F” Waste in CT
  36. F006 (T) F019 (T) Wastewater treatment sludge from electroplating operations except from the following processes: (1) sulfuric acid anodizing of aluminum; (2) tin plating on carbon steel; (3) zinc plating on carbon steel; (4) aluminum or zinc-aluminum plating on carbon steel; (5) cleaning/stripping associated with tin, zinc, aluminum plating on carbon steel; (6) chemical etching of aluminum. Wastewater treatment sludge from chemical conversion coating of aluminum except zirconium phosphating in aluminum can washing (beer and soda exemption) Common “F” Waste in CT
  37. Listed Hazardous Waste“Specific Source” “K” Waste Codes(261.32) Waste from specifically identified industrial sources: K001 – K160 Refineries (K048, K170) Pharmaceutical (K084, K101) Foundry (K061, K069) Explosives (K044, K45)
  38. Example
  39. Listed Hazardous Waste“Commercial Chemical Product”“U” & “P” Waste Codes(261.33) Waste that is a commercial product solvents pesticides Pharmaceuticals Chemical ingredients
  40. Commercial Chemical Product,continued Waste chemical product that is unused pure or technical grade of chemical sole active ingredient A waste because: no longer needed or wanted off-specification old/outdated
  41. Commercial Chemical Product,continued Spilled virgin chemical product discarded (spilled on non-soil) disposal (spilled on soil/water)

  42. “P” Commercial Chemical Productexamples

    “acutely hazardous” P001 - P205(H) Empty containers of “P” listed materials (unless triple rinsed) Rinsate from rinsing empty containers

  43. “U” Commercial Chemical Productexamples

    U001 – U411(T)
  44. QUESTIONS Discarded Disposed Listed hazardous waste Mixture rule
  45. Characteristic Hazardous Wastes(261.21 – 24) Four waste types “D” waste codes Ignitable (D001) Corrosive (D002) Reactive (D003) Toxicity Characteristic (D004-D043)
  46. Some Facts About Characteristic Hazardous Waste All solid waste must be evaluated for the characteristics Paper Tires Chemicals Lamps Electronic equipment Paint Scrap metal Building debris
  47. Some Facts About Characteristic Hazardous Waste Some characteristics are based on physical properties flash point pH compressed or pressurized gases oxidizer
  48. Some More Facts Some characteristics are based on concentration limits (toxic above the limits) milligrams per liter (mg/L) test method “Toxicity Characteristic Leachate Procedure” limits range between 0.008 to 400 mg/L note: one percent (1%) equals 10,000 ppm
  49. Ignitable Characteristic“D001”(261.21) Liquid with a flashpoint less than 140 degrees Oxidizers (49 CFR 173.151) Ignitable compressed gas (49 CFR 173.300) Not a liquid – fire through friction, moisture, spontaneous chemical change, & burns vigorously and persistently
  50. Ignitable CharacteristicExamples Liquid – flash point less than 140 Mineral spirits Contact cement Aerosol paint Oxidizers Nitric acid Peroxides Fertilizer (sodium nitrate) Ignitable compressed gas Aerosol products Propane Not a liquid Metal fines and chips aluminum, zirconium, magnesium
  51. Corrosive Characteristic“D002”(261.22) Aqueous liquid, pH less than 2 or greater than 12.5. A liquid that corrodes steel at greater than 0.025 inches per year at 130 degrees F.
  52. Corrosive Characteristicexamples pH less than 2 Nitric acid (etch) Sulfuric acid (battery) Muriatic acid (concrete) Hydrofluoric (aluminum) pH greater than 12.5 Potassium hydroxide (oven) Sodium hydroxide (drain) Ammonium hydroxide (cleaner) Sodium hypochlorite (bleach)
  53. Reactive Characteristic“D003”(261.23) Normally unstable Reacts violently with water or forms toxic fumes or vapors Capable of detonation or explosion when heated under confinement or initiating force
  54. Reactive CharacteristicExamples Explosives Fire works Ammunition Air bags Old picric acid Old ether Compressed cylinders Aerosol cans Propane cylinders Metal fines Aluminum Lithium Batteries with a charge
  55. Toxicity Characteristic “D004 - D043”(261.24) 39 elements and compounds cause damage to tissue, impair CNS, cause severe illness or death when ingested, inhaled, or absorbed. based on concentration limits (mg/L). testing using Toxicity Characteristic Leachate Procedure.
  56. List of Toxicity Characteristic Waste Waste Code Contaminant Limit mg/L D004 arsenic 5.0 D005 barium 100.0 D006 cadmium 1.0 D007 chromium 5.0 D008 lead 5.0 D009 mercury 0.2 D010 selenium 1.0 D011 silver 5.0 D012 endrin 0.02 D013 lindan 0.4 D014 methoxychlor 10.0 D015 toxaphene 0.5 D016 2,4-D 10.0
  57. Waste codeContaminantLimit mg/L D017 2,4,5-TP 1.0 D018 benzene 0.5 D019 carbon tetrachloride 0.5 D020 chlordane 0.03 D021 chlorobenzene 100.0 D022 chloroform 6.0 D023 o-cresol 200.0 D024 m-cresol 200.0 D025 p-cresol 200.0 D026 cresol 200.0 D027 1,4-dichlorobenzene 7.5
  58. Waste codeContaminantLimit mg/L D028 1,2-dichloroethane 0.5 mg/L D029 1,1-dichloroethylene 0.7 mg/L D030 2,4-dinitrotoluene 0.13 mg/L D031 heptachlor 0.008 mg/L D032 hexachlorobenzene 0.13 mg/L D033 hexachlorobutadiene 0.5 mg/L D034 hexachloroethane 3 mg/L D035 methyl ethyl ketone 200 mg/L D036 nitrobenzene 2 mg/L D037 pentachlorophenol 100 mg/L D038 pyridine 5 mg/L D039 tetrachloroethylene 0.7 mg/L D040 trichloroethylene 0.7 mg/L D041 2,4,5 trichlorophenol 400 mg/L D042 2,4,6 trichlorophenol 2.0 mg/L D043 vinyl chloride 0.2 mg/L
  59. Examples Lead Silver Mercury Chromium 2,4-D Benzene Tetrachloroethylene Pentachlorophenol Paint, wire coating, electronics, gun range, electroplating, fly ash, foundry, batteries X-ray & photo developing, electronics, electroplating, batteries Batteries, lamps, switches, dental fillings Electroplating, paint, fly ash, foundry Weed & feed products Gasoline, oil, labs Aerosol degreasers, dry cleaners Egg farms, wood preservers
  60. Questions ignitable corrosive reactive test methods toxicity characteristic
  61. The Other RCRA Waste Hazardous wastes that can be managed under reduced requirements– Used Oil (40 CFR 279) Universal Waste (40 CFR 273)
  62. Used Oil “Any oil refined from crude oil or any synthetic oil, that has been used and as a result of such use is contaminated by physical or chemical impurities” Lube oil (crank case, tub/wire drawing) Heat transfer oil (machining, hot plate) Hydraulic oil Does not include animal or vegetable oil
  63. Used Oil(40 CFR 279) Used oil includes filters & absorbents Can exhibit a HW characteristic or be listed HW Presumed to be recycled (disposed = full regulation) Must test for total halogens > 1000 ppm halogens - presumed mixed with hazardous waste. - halogenated solvents (100 ppm = HW)
  64. Used Oil Generators(40 CFR 279) Don’t have to get EPA Id. No. Burn in an on-site space heater Can take from residential DIY No storage time or quantity limits 1340-gallons petroleum waste and/or product – SPCC Plan Can be sold as fuel Off-spec – industrial boilers/furnaces regulated under Part 266 On-spec – to anyone non-residential in CT.
  65. Used Oil Fuel Specifications On-specification used oil fuel Arsenic 5 ppm Cadmium 2 ppm Chromium 10 ppm Lead 100 ppm Flash point 100 F Total halogens 4000 ppm Off-specification used oil fuel Exceed any of the above
  66. Universal Waste Rule(40 CFR 273) Waste generated at any type of business Manufacturers Repair shops Office buildings Hotels Casinos Are a listed or characteristic HW Except for some FIFRA recalled pesticides
  67. Universal Waste The universal waste: Batteries (HW corrosive, heavy metals) Lead-acid, NiCad, Hg cell, Li cell, Ag cell Thermostats (HW mercury) Lamps (HW mercury) FIFRA recalled pesticides
  68. Universal Waste States can add other HW Mercury containing equipment (HW mercury) All fluorescent lamps (HW & non-HW mercury) Used electronics (HWlead, silver, mercury)
  69. Universal Waste EPA Id. No., only if handling <5000 kilograms Store for up to one year Handle in an environmentally safe manner Spilled/released becomes fully regulated HW Ship to other UW handler Still UW Ship to final destination facility TSDF or permit exempt recyclers Becomes fully regulated HW
  70. In the works Many states are considering adding pharmaceuticals Being pushed by hospitals and pharmacies “P” and “U” listed waste Warfarin Nicotine Epinephrine Characteristic waste Heavy metal compounds Mercury, selenium, barium, chromium Pesticides Lindan Ignitable liquids
  71. Questions Used oil & handling requirements Universal Waste & handling requirements

  72. Some Statistics

    Virgin (waste) Oil 29,000,000 gallons/year run-off into oceans 85% land run-off (24,650,000 gallons) 8% pipeline and oil tanker (2,320,000 gallons) 3% oil exploration (870,000 gallons)

  73. Some Statistics

    Used Oil 1,378,000,000 gallons/year generated 67% burned as fuel (928,000,000 gallons) 13% illegally disposed (185,000,000 gallons) 10% landfilled (140,000,000 gallons) 4% rerefined (56,000,000 gallons)

  74. Some Statistics

    Used Oil Filters 400,000,000 filters/year generated 90% illegally disposed (360,000,000) 10% recycled (40,000,000) 1 ton recycled filters equals 1,700 pounds of steel 60 gallons of oil

  75. Some Statistics

    Lead-acid Batteries 70,000,000 Batteries/year generated 20 pounds lead/2 gallons acid 80% are recycled (56,000,000) 20% are disposed (14,000,000) 280,000,000 pounds lead disposed 28,000,000 gallons acid disposed
  76. Some Statistics Mercury Containing Lights 600,000,000 Waste bulbs/year 14 to 80 milligrams mercury/bulb Pre 1996, most disposed Post 1996: 80% recycled (480,000,000 bulbs) 20% disposed (*120,000,000 bulbs) * About20,000 pounds of mercury disposed each year
  77. Some Statistics Mercury Switches Car trunk/hood lights 200,000,000 car light switches since 1979 Pre 2003 – most where crushed with the car Post 2003 – most recovered as universal waste
  78. Some Statistics Used Electronics 2,600,000 tons discarded per year Most goes to landfills and incinerators. 140,000,000 are cell phones Many end up in foreign countries
  79. Sources of Assistance David Stokes, DEP Waste Management 860-424-3269 E-mail – david.stokes@po.state.ct.us DEP Compliance Assistance Phone Line Toll free 888-424-4193 RCRA main line 860-424-3023
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