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Heritage University Hazardous Waste Regulatory Review Course

Heritage University Hazardous Waste Regulatory Review Course. Conducted by: Gary F. Lindgren, CHMM Heritage Environmental Services, LLC. Hazardous Waste Regulatory Program Overview. Hazardous Waste Regulatory Program Overview. Resource Conservation and Recovery Act (RCRA), As Amended

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Heritage University Hazardous Waste Regulatory Review Course

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  1. Heritage UniversityHazardous Waste Regulatory Review Course Conducted by: Gary F. Lindgren, CHMM Heritage Environmental Services, LLC

  2. Hazardous Waste Regulatory Program Overview

  3. Hazardous Waste Regulatory Program Overview • Resource Conservation and Recovery Act (RCRA), As Amended • Waste Inventory/Hazardous Waste Determination/ Determination of Regulatory Status • Notification - EPA Identification Numbers for Generators, Transporters, and TSD Facilities

  4. Hazardous Waste Regulatory Program Overview • Permits for Treatment, Storage, and Disposal (TSD) Facilities (Permits Not Required for 90 Day Accumulation in Containers/tanks) • Standards for Generators, Transporters, and TSD Facilities • Treatment Standards for Wastes Before Land Disposal, and Minimum Technology Requirements for Land Disposal Facilities

  5. Hazardous Waste Regulatory Program Overview • Use of manifest for transportation • State regulatory programs - authorization • Inspections and enforcement • Requirements for clean-up and ultimate responsibility of generator for disposition and environmental impact of waste -"Cradle to Grave"

  6. Basic Requirements of Hazardous Waste Generators

  7. Basic Determinations • Identify Wastestreams • Hazardous Waste Determination • Determination of Regulatory Categories

  8. Container Management Standards Containers Must Be . . . • In Good Condition • Compatible With the Waste • Labeled or Marked Clearly With the Words "Hazardous Waste" • Marked With the Accumulation Start Date

  9. Container Management Standards (cont’d) • Kept Closed • Managed to Avoid Damage and Releases • Incompatible Wastes Are Not to Be Placed in the Same Container. • Subpart CC Air Emissions Standards May Apply.

  10. Container Accumulation Area Standards • Ignitable/reactive Wastes Must Be 50 Ft. From the Property Line • "No Smoking" Signs Must Be Posted • Incompatible Wastes Are to Be Separated or Protected From Each Other • Emergency Equipment Is to Be Available • Adequate Aisle Space (2½ Feet) Is to Be Maintained

  11. Container Accumulation Area Standards (cont’d) • Inspect Container Accumulation Areas Weekly • Inspect Emergency Equipment at Least Monthly • Shipments Are to Be Made Every 90 Days for Large Quantity Generators • Shipments Are to Be Made Every 180 Days for Small Quantity Generators

  12. Compliance Documentation • Contingency Plan • Personnel Training Program & Records • Inspections • Manifests and LDR Forms • Biennial Reports • Waste Analyses/Determinations • Waste Minimization Program

  13. EPA’s “New” Definition of Solid Waste (40 CFR 261.2)

  14. Any Material • Disposed of or Abandoned in Lieu of Disposal • Burned, Incinerated or Recycled • “Inherently Waste-like”

  15. Exclusions “Materials Which Are Not Solid Wastes” (40 CFR 261.4(a)) • Domestic Sewage Exclusion • Point Source (NPDES) Exclusion • Secondary Materials That Are Reclaimed and Returned to the Original Process(es) in Which They Were Generated Where They Are Reused in the Production Process

  16. “Solid Wastes Which Are Not Hazardous Wastes”(40 CFR 261.4(b))

  17. Pertinent Exclusions • Household Wastes • Fossil Fuel Wastes, Except Provided by 40 CFR 266.112 • Cement Kiln Dust, Except Provided by 40 CFR 266.112

  18. Pertinent Exclusions(cont’d) • Petroleum-Contaminated Media and Debris (D018-D043 Only) From Regulated UST Releases • Non-terne plated used oil filters if gravity hot-drained

  19. Pertinent Exclusions(cont’d) • Samples (40 CFR 261.4(d)) • Treatability Study Samples (40 CFR 261.4(e)&(f)) • CESQG Hazardous Wastes (40 CFR 261.5) • Specified Recyclable Materials (40 CFR 261.6)

  20. Pertinent Exclusions(cont’d) • Residues In Empty Containers (40 CFR 261.7) • PCB Wastes Exhibiting the Toxicity Characteristic (D018-D043) Regulated Under TSCA (40 CFR 261.8) • Universal Wastes (40 CFR 261.9, Referencing 40 CFR Part 273)

  21. Pertinent Exclusions(cont’d) • Product or Raw Material Storage Tank Residues; Residues in Product or Raw Material Transport Vehicles, Vessels or Pipelines; and Residues in Manufacturing Process Units While These Units Are in Service (40 CFR 261.4(c))

  22. Recycling Exemptions(40 CFR 261.2)

  23. Five Types of Materials • Spent Materials • Sludges • Byproducts • Commercial Chemical Products • Scrap Metal

  24. Four Types of Recycling Activities • Use Constituting Disposal • Burning Waste or Waste Fuels for Energy Recovery or Using Wastes to Produce a Fuel • Reclamation of Wastes • Speculative Accumulation

  25. Only Combinations Not Considered Solid Waste • Reclamation of Sludges (non-listed) • Reclamation of Byproducts (non-listed) • Reclamation of Commercial Chemical Products • Speculative Accumulation of Commercial Products

  26. Note • Recycling of Scrap Metal Is Excluded From Regulation at 40 CFR 261.6(a)(3)(ii). • Recycling of Characteristically Hazardous Used Oil in a Manner Other Than Blending or Burning Is Excluded From Regulation at 40 CFR 261.6(a)(4). Characteristically Hazardous Used Oil Reclaimed by Blending or Burning Is Regulated at 40 CFR Part 279.

  27. Materials That Are Used/Reused(40 CFR 261.2(e)(1)) Materials are Not Solid Wastes Subject to Regulation When Use/Reuse Resembles Ordinary Production Operations or the Use of Commercial Materials.

  28. Product Use • Direct Use/Reuse as Ingredient or Feedstock in Production Processes • Direct Use/Reuse as Effective Substitute for Commercial Product • Return to Original Production Process in Which They Were Generated Without First Being Reclaimed

  29. Exceptions • Materials Used in a Manner Constituting Disposal, or Used to Produce Products that are Applied to the Land • Materials Burned for Energy Recovery, Used to Produce a Fuel or Contained in Fuels • Materials Accumulated Speculatively

  30. Exceptions (cont’d) • Inherently Waste-like Materials Listed at 261.2(d)(1) F020-F023, F026 and F028 • No “Reclamation”, as Defined

  31. Solid Waste/Hazardous Waste Determinations (40 CFR 261.3)

  32. Waste Material • Excluded From Definition of Solid Waste (40 CFR 261.4(a) or by Reuse or Recycling)

  33. Solid Waste • Excluded from Definition of Hazardous Waste (40 CFR 261.4(b))

  34. Hazardous Waste • Listed (40 CFR 261, Subpart D • Mixture of Solid Waste and Listed Hazardous Waste (40 CFR 261.3(a)(2)(iv)) • Solid Waste Derived from T, S, or D of Listed Hazardous Waste (40 CFR 261.3(c)(2)(i)) • Waste Exhibits any Characteristics of Hazardous Waste (40 CFR 261, Subpart C - either by testing or knowledge of waste)

  35. Lists of Hazardous Wastes(40 CFR Part 261, Subpart D) F-list K-list P-list U-list

  36. “Hazardous Wastes from Non-Specific Sources” (40 CFR 261.31) “F-List”

  37. Generic Industrial Process Wastes • Spent Solvents (F001-F005) (Not Commercial Products or Manufacturing Process Wastes) - “Solvent Mixture Rule” • Electroplating Wastes (F006, F007, F008, F009)

  38. Generic Industrial Process Wastes (cont’d) • Metal Heat-Treating Wastes (F010, F011, F012) • WWT Sludges from Chemical Conversion Coating of Aluminum (F019) • Miscellaneous

  39. “Hazardous Wastes from Specific Sources” (40 CFR 261.32) “K-List”

  40. Process Wastes from Specified Industries • Wood Preservation • Inorganic Pigments • Organic Chemicals • Inorganic Chemicals • Pesticides • Explosives

  41. Process Wastes from Specified Industries (cont’d) • Petroleum Refining • Iron & Steel • Primary Copper • Primary Lead • Primary Zinc • Primary Aluminum

  42. Process Wastes from Specified Industries (cont’d) • Ferroalloys • Secondary Lead • Veterinary Pharmaceuticals • Ink Formulation • Coking

  43. Acute Hazardous (H) Wastes (40 CFR 261.33(e)) “P-List”

  44. P-List Examples • Mostly Pesticides, Organic Chemicals, Cyanides, and Certain Heavy Metal Compounds • Listings Include Unrinsed Containers/Liners and Spill Residues • Lower Small-Quantity Generator Exclusion (1 Kilogram/100 Kilograms Spill Residue)

  45. Toxic (T) Wastes (40 CFR 261.33(f)) “U-List”

  46. U-List • Mostly Natural and Synthetic Organics • Listings Include Spill Residues

  47. Note Commercial chemical product listings do not apply to spent materials or manufacturing process wastes containing listed chemicals. Listings apply to technical grade chemicals or formulations where the listed chemical is the sole active ingredient. The commercial chemical products listings apply if and when such chemicals are spilled, discarded or intended to be discarded. Listings should be consulted prior to disposal of virgin chemical spill residues, off-specification chemical products, manufacturing chemical intermediates, obsolete chemical inventory, excess or surplus inventory, or expired chemical products.

  48. Characteristics of Hazardous Waste (40 CFR Part 261, Subpart C)

  49. Ignitability (I) D001 (40 CFR 261.21) • Liquid, With Closed Cup Flashpoint <140°F • Nonliquid, Capable of Spontaneous and Sustained Combustion and When Ignited, Burns So Vigorously and Persistently As to Create a Hazard • DOT Oxidizers and Ignitable Compressed Gases

  50. Corrosivity (C) D002 (40 CFR 261.22) • Aqueous, pH £ 2 or pH ³ 12.5 • Liquid, Corrodes SAE 1020 Steel > 1/4" Per Year at 130°F

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