Presentation Transcript

1. Where did it go? Keeping Track of your Hazardous Wastes

   Tom Ezell Programs Branch ADEQ Hazardous Waste Division
2. There is no such place as “Away,” where you can freely throw things…
3. Managing Wastes Treating, storing and getting rid of hazardous waste means different things to different people. Owners of businesses-comply with State and Federal law. Government official-ensure no harm to people or property. Concerned citizen-want assurance that everyone handling any sort of waste knows what to do.
4. What Was It Like Before 1976? Rivers, lakes and streams polluted. News stories everyday concerning random dumping. “The Valley of the Drums” near Louisville, KY (1976) Cuyahoga River Cleveland, OH (1969)
5. Love Canal Niagara Falls, NY 1978 Cuyahoga River burns – 1952 & 1969 Old Midland Wood Treating, Ola, AR 1984 Diaz Refinery, Newport, AR 1989 Griffing Railway, El Dorado, AR 1991 Red River Aluminum, Stamps, AR 2000 Cedar Chemical, Helena, AR 2002
6. Two Approaches to the Problem RCRA: Ensure industrial wastes are safely managed and disposed Superfund: Identify and clean up old and abandoned toxic sites.
7. What Do I Have to Do? State and Federal law require you to: Determine if you generate hazardous waste in the first place. Measure the amount of hazardous waste that you produce per month. Determine your generator category to learn the waste management requirements that apply to you. If an LQG or SQG, obtain an EPA identification number from ADEQ.
8. Classifications of Generators Conditionally Exempt Small Quantity Generators (CESQG) - § 262.35 Less than 220 lb non-acute hazardous waste Less than 220 lb acute spill cleanup Less than 2.2 lb of acute hazardous waste Small Quantity Generators (SQG) - § 262.13 Between 220 lb and 2200 lb of non-acute hazardous waste Less than 220 lb of acute spill cleanup Less than 2.2 lb of acute hazardous waste Large Quantity Generators (LQG) - § 262 Greater than 2200 lb of non-acute hazardous waste Greater than 220 lb of acute spill cleanup Greater than 2.2 lb of acute hazardous waste
9. Notification If your business generates between 220 lbs (100 kg) and 2,200 lbs (1,000 kg) of hazardous waste per month, you are an SQG, and you must obtain and use an EPA Identification Number. EPA and states use these 12-character numbers to monitor and track hazardous waste activities. You will need to use your identification number when you send waste off site to be managed. To obtain an EPA ID Number: Call ADEQ to determine if you need an EPA identification number. If you do, obtain a copy of ADEQ Form 8700-12. (Site Identification Form) Fill in the form completely. Send the form to ADEQ.
10. Uniform Hazardous Waste Manifests EPA form 8700-22 tracks the waste from “Cradle to Grave”. Passed from one person to the next in the chain. The Manifest Identifies: Type and quantity of waste. The transporter. TSD where waste is being shipped.
11. MANIFEST, continued Generator must sign the manifest, ensure packaging and labeling meet DOT requirements, obtain transporters signature and supply at least six copies of the manifest.
12. Generator Must be Notified of receipt In 35 days; or call your transporter and TSDF to find out where the waste is. In 45 days; or call the ADEQ.
13. Transportation and Shipping Package, label, and mark your shipment, and placard the vehicle in which your waste is shipped as specified in DOT regulations. Prepare a hazardous waste manifest to accompany your shipment. Include an LDR notice and certification with each waste shipment. Use a permitted hazardous waste transporter for your shipment. Ensure the proper management of any hazardous waste you ship (even when it is no longer in your possession).
14. Annual Reporting Reg. No 23 § 262.41 requires SQGs and LQGs to report the types and amount of hazardous wastes generated, treated, or disposed each year. Report is due March 1 of each year, based on previous year’s generation. Report may be submitted electronically using software provided by ADEQ, or on paper forms provided on request. An annual generation fee is assessed for waste generation of more than 30,000 lbs. each year.
15. http://www.arminc.net/Applications/Easitrak2012/Security/Login.aspx http://www.arminc.net/Applications/Easitrak2012/Security/Login.aspx Submitting the Annual Report Arkansas, like many other states, collect this information electronically. Submitted on-line using “EasiTrak” software. Large commercial facilities may use formatted flat files. Paper forms remain an option.
16. For a new user you must click on the “Registration for Generator” link. If you have already registered, you only will need to enter your EPA ID number and your Password.
17. The next screen will allow the user to enter their EPA ID number, email address, and password. Also there are 4 security questions you must answer and will be asked for these answers to submit your report to the State.
18. Select the NAICS category by choosing a number from 1 to 9. This will display a category listing of NAICS codes.
19. Select the EPA Waste Code category and use the “Add >” key at the bottom to move the waste code to the right. If you accidentally add the wrong waste code use the “<Remove” key. IMPORTANT to Save your data select the “Done” button at bottom of the screen.
20. Review of HW Reporting with Easitrak Remember you have to register each reporting year as a new user and you answer security questions you will need when you submit your report You do not have to complete the report at one sitting, just the screen you are working in, remember to save your data Remember to use icons to have pop up screens for data entry. Remember for addresses enter your zip code first and then pick the correct city from the pop up screen. Once you have completed your report you will need to select “Check Data”. If your data passes you can submit your data, remember additional form(s) you mail have to sign and mail in to ADEQ. Always go to our support page at www.arminc.net. Assistance is available by emailing ARM at info@arminc.net
21. Records: What to Keep Weekly inspection records for hazardous waste management units. (262.34) Annual Hazardous Waste Reports (262.41) Manifests & Exception Reports (262.23(a); 262.42) Any test results used to determine if a particular waste stream is hazardous (262.11) Employee training records (265.16(d)) LDR Notices and certifications (268.7(a)(8))
22. Records Retention Manifests – 3 years from the shipment date LDR Certifications – 3 years from the last date the waste was shipped off site Training Records: Current Employees – As long as the facility continues to operate. Former Employees – 3 years from the last date that employee worked for the company.
23. Coming developments… MyRCRAID: Submit and update notifications on-line. ePermitting: Apply for and update ADEQ permits on-line. E-Manifest: Maintain manifests on-line via a federal web site.