Industrial Radiography RCRA Workshop Part II

1. Industrial Radiography RCRA Workshop Part II August 25, 2010, 10:30-12:30 Presented by Christina Coffel Oklahoma Department of Environmental Quality Land Protection Division Hazardous Waste Compliance Section

2. Safety & Comfort First • Public Announcement (PA) will alert for all emergencies. In the event of a fire, exit out the front door, gather in the north parking lot for a head count. • No smoking on DEQ grounds. You can smoke across the street. • Vending Machines: Located on the 7th floor, after exiting the elevators, go east to the end of the hall. Break room is on the right. North 

3. Review from First RCRA IR Workshop Generator status--------------------------LQG, SQG, CESQG Generation points-------Main location vs. remote locations Silver reclamation --------------------Minimum level 5 mg/L Transporter issues----------------Should facility be notified Reclamation documentation---Manifest use requirements Rinse water discharge----Authorized discharge points only

4. RCRA 1. Waste Determinations: • You need to make waste determinations for all waste generated by the facility. Determinations made by either testing or knowledge of process. Is it a solid waste? If yes, Is it a hazardous waste? If yes, Is it a characteristic waste or a listed waste or both? If yes, Are there any exemptions that apply?

5. Waste Determinations • Point of Generation: Waste becomes subject to regulation when: • It is removed from the manufacturing process unit, OR • 90 days after the unit is taken out of service if the waste remains in an inactive unit…” • Apply to both mobile and stationary units.

6. Industrial Radiography Common Hazardous Waste Streams Waste film—may exhibit the toxicity characteristic for silver (D011) Waste solutions –may exhibit the toxicity characteristic for silver & possibly for corrosivity(D002). Waste Fixer Waste Developer Waste Rinse Water

7. Industrial Radiography Common Hazardous Waste Streams cont… If vehicle maintenance performed on site: Used Batteries--may exhibit the toxicity characteristic for corrosive and lead (D002 &Doo Used Antifreeze (60/40 Hazardous Guidance) Used Oil & Used Filters Used Fluorescent Lamps-- may exhibit the toxicity characteristic for mercury (D009)

8. Waste Film • Usually contains silver above the RCRA limit of 5.0 mg/L using TCLP. • Can recycled under the precious metals exemption, 40 CFR 266 Subpart F. • Hazardous waste determination: • Can either test film (TCLP) to determine level (make sure test is a representative sample of all possible exposures for accurate silver levels) • OR, assume it will exhibit the toxicity characteristic for silver. • OR, use knowledge of process—supporting information/documentation required.

9. Waste Solutions Waste Fixer & Waste Developer & Waste Rinse Water • Can be separated in process to reduce quantity of HW generated or combined into one waste container. • Silver recovery unit must be used as per the manufacturers instructions. • Periodic testing should occur to ensure recovery unit is operating at optimum levels. • After recovery, the waste waters should be below RCRA limit of 5 mg/L silver. • May need more than one recovery unit to accomplish this. • Recovery cartridges are considered a sludge if going for recovery, not a RCRA waste so you don’t have to count their weight in your monthly generation amounts (see future slide) • If you use test strips, verify the range of the strip!

10. Used Lamps • Lamps qualify to be managed under the Universal Waste (UW) regulations which are less stringent than the full hazardous waste regulations. • UW containers must be compatible, labeled, and dated with an accumulation start date or tracking system. • One year storage limit vs. 90-day (LQG), or 180-day (SQG). • No manifest usage required. Bill of Lading sufficient or internal tracking system. • Does require UW employee training.

11. Vehicle Wastes Used Oil (UO) & Used Filters • 40 CFR 279 • Label Containers “USED OIL” • Use authorized UO Recycler & Transporter Used Antifreeze: • EPA 60/40 Hazardous Guidance

12. Vehicle Wastes cont… Used Batteries • Can be managed as HW, UW, or under special exemption: 40 CFR 266 Subpart G • If core-exchanging, then it is easiest to use the exemption. • Generators responsible to ensure proper recycling is occurring by the company accepting the battery for recycling-perform due diligence before sending for recycling

13. RCRA 2. Generator Status Determinations: • You need to determine how much hazardous waste you will generate each month in order to establish which hazardous waste generator category you will be in. Large Quantity Generator (LQG) generate over 2, 200 pounds HW per month Small Quantity Generator (SQG) generates 220 to 2,200 pounds HW per month Conditionally Exempt Small Quantity Generator (CESQG) generates 0 to 220 pounds HW per month

14. Waste Generation: What to Count? Only count the hazardous waste weight! Do not count waste that is managed as Universal Waste. Do not count Used Oil.

15. LQGs 2,200 lbs or more HW generated monthly • Required Notification for an EPA ID# • Must use a manifest/LDR • Disposal Plans & Annual Fees • Quarterly Reports & Biennial Reports • Written Contingency/Emergency Plans

16. LQGs cont… • Notification to local authorities • Well documented Employee Training Programs • Documented weekly HW storage inspections • 90-day HW storage limits & NO weight limit for storage • Storage containers must be closed, appropriately labeled, and dated • Must perform and document weekly storage area inspections

17. SQGs 220 lbs –2,200 lbs HW generated monthly • Required Notification for an EPA ID# • Must use a manifest /LDR • Annual Fees • Written Contingency/Emergency Plans

18. SQGs cont… • Notifications to local authorities • Employee training Programs • Weekly HW storage inspections • 180-day HW storage limits & no more than 13,228 lbs (6,000 kg) on site at any given time • Storage containers must be appropriately closed, labeled, and dated

19. CESQGs Up to 220 lbs HW generated monthly • Not required to notify EPA • Not required to use a manifest, bill of lading sufficient • Destination facility must be authorized to accept the waste • Recycling facility must be a legitimate recycler • Limited to no more than 2,200 lbs HW on site at any given time • No time limit for storage

20. Container Management Storage vs. Satellite Accumulation Definition of CLOSED Labeling Accumulation start date

21. Container Management • Satellite Accumulation Area • At or near the point of generation, • Under the supervision of the operator, • Not exceeding 55 gallons per SAA, • Only three day allowance to move full SAA to container storage. • Storage containers are used to store hazardous waste awaiting disposal or recycling. Usually stored in a centralized location. • The amount of storage is limited by the generator status. No limit on the number of SAA allowed.

22. Container Management • Both types of containers must be closed. • DEQ defines closed as spill proof and vapor tight. • Both containers must be labeled. Storage with the words “Hazardous Waste”, SAA with a content identifying label.

23. Container Management • Storage containers require an accumulation start date on the container. • identifies the first day the container became a storage container. This date will show how long it has been on site so as to comply with the generator storage limits (90-days LQG or 180-days SQG). • A SAA may become a storage container when it is deemed full or moved to the container storage area. • At this point it needs a date and the words “Hazardous Waste”.

24. Precious Metals Exemption 40 CFR 266 Subpart F: Silver Reclamation

25. Silver Reclamation Exemption • Materials that are reclaimed to recover economically significant amounts of gold, silver, platinum, palladium, iridium, osmium, rhodium, ruthenium, or any combination of these. • Applicable to any persons who generate, transport, or store recyclable materials that are regulated under this subpart. Required to: • Notify EPA • Use the manifest if a generator, transporter, or someone who stores.

26. Silver Reclamation Exemption • Anyone who stores recycled materials that are regulated under this part must keep the following records to document they are not accumulating these materials speculatively • Records showing the amount of materials stored at the beginning of the calendar year; • The amount of these materials generated or received during the calendar year; and • The amount of material remaining at the end of the calendar year. • If speculative accumulation occurs, all regulations apply! • If sent out of the country, specific EPA reporting required.

27. Hazardous Waste Transporting Generating at a remote location and transporting the hazardous waste back to the main location

28. Transporting Hazardous Waste Requires: • EPA notification of activity, • Licensing from DOT, • Authorization from OCC. Knowledge of manifesting requirements Specific employee/driver training

29. Transporting Hazardous Waste If generator is a CESQG: • Can self transport (limited amounts). • No HW manifesting required. • Be very familiar with the CESQG exemption-- • 40 CFR 261.5 • Be careful with timing of waste generation, this may affect your generator category. Some CESQGs can become SQGs based on the timing of waste disposal. Then all SQG rules apply for that month of SQG generation.

30. Final Guidance will be posed on the DEQ website: http://www.deq.state.ok.us/LPDnew/HW/Industrial%20Radiography%20Silver%20Recl%20from%20Xray%20Develpmt%2011-2010.pdf

31. Oklahoma DEQ Contacts Hazardous Waste Compliance Section Phone (405) 702-5226 (405) 702-5176 (405) 702-5189 (405) 702-5219 (405) 702-5100 (405) 702-5101 Mike Edwards, Manager Christina Coffel, Inspector Al Coulter, Data Management Jarrett Keck, Reporting Any other HWCS member Facsimile