Proper Material Storage and Disposal of Wastes

1. Proper Material Storage and Disposal of Wastes Employee Training Series Green Country Stormwater Alliance (GCSA) May 19, 2017 Prepared by INCOG

2. Proper Handling of Chemicals This presentation provides suggestions and ideas for the safe handling, storage and cleanup of materials used by municipal workers.

3. Proper Handling of Chemicals • Hazardous material storage, handling and disposal regulations are complex and a complete understanding is beyond the scope of this presentation. • Unless you have received specific training and feel competent in this highly regulated field, you will need the support of a waste management company, environmental consultant or need to develop a good working relationship with ODEQ and EPA.

4. Store and Handle Materials Safely • Have safety data sheets (SDS) on hand for all hazardous materials in the work area. • The SDS will inform you of: • Chemical, physical & toxicological properties • Safe handling recommendations • Precautionary information • Fire & explosion potential • Personal hazards • Safe disposal procedures

5. Revised Hazard Communication Standard (HCS) • OSHA revised its Hazard Communication Standard (HCS) to align with the United Nations’ Globally Harmonized System (GHS) of Classification and Labeling of Chemicals. • OSHA believes the new label elements and Safety Data Sheet (SDS) requirements will improve worker understanding of the hazards associated with the chemicals in their workplace. • The new requirements were expected to be fully implemented by June 1, 2016.

6. Pictograms Exploding Bomb Oxidizers Exclamation Mark Skull & Crossbones Environment Corrosion Gas Cylinder Health Hazard Flame

7. Store and Handle Materials Safely • Read and follow the label and SDS instructions and comply with local, state and federal requirements. • Notify your local fire department of amounts, location and the toxic, flammable or explosive nature of stored materials if necessary. • Post the proper placards on building entrances where hazardous materials are stored.

8. Store and Handle Materials Safely • Store materials in original containers if possible. If not, clearly label the replacement containers. • For additional information on the safe storage of hazardous materials in Oklahoma, call Public Employee Occupation, Safety & Health at 405-528-1500 x 226.

9. Store and Handle Materials Safely • Before reusing a container for another product, remove or obscure the old label. • Use a waterproof marker to write directly on the container or on a new permanent label. • The replacement container must be compatible with the product your are putting in it.

10. Store and Handle Materials Safely • At a minimum, a proper label should contain: • Name of the product (same as on SDS) • Name and address of the manufacturer • Appropriate hazard information • Lot or identification number • Expiration date • The label must be legible and it is a good idea to date and initial the container when it is opened.

11. Store and Handle Materials Safely • Make sure containers are closed or sealed except when they are being filled or emptied. • Inspect storage areas weekly to quickly detect signs of corrosion or leakage and keep an inspection log. Promptly replace any leaking container.

12. Store and Handle Materials Safely • Store materials in their original, sealed containers indoors if possible. • If they must be stored outdoors, store them in sealed containers, on a secured, paved area and protected from the elements if necessary.

13. Store and Handle Materials Safely Spill trapping devices are recommended and may be required in some cases. • Indoors: store barrels on a spill containment base. • Outdoors: storage areas should be bordered by a curb or berm to contain spills. • Do whatever is necessary to contain leaks and spills and prevent releases to water bodies.

14. Store and Handle Materials Safely • Salt and salt/sand storage areas should be covered and have an impervious floor. Outside piles must be bermed to prevent salt and sand from escaping the site. • The CERCLA regulations list the hazardous materials and spill volumes that must be reported to DEQ and the National Response Center. Consult this list for chemicals and volumes.

15. Be Prepared • To prepare for future spills and emergencies, develop an Emergency Action Plan for your facility. • This process will force you to consider what could go wrong, require you to think about how it would be best handled and then allow you to develop an appropriate response. • This plan should cover everything from small spills to natural disasters.

16. Be Prepared • Distribute the plan to all employees, the fire department and any emergency response organization that might respond to a call for help from your organization. • Post the Plan • Know the location of: Alarm stations, eyewash/showers, fire extinguishers, exits, SDS, spill equipment, personal protective gear and emergency phone numbers.

17. Spill Response • Determine whether it is an incidental spill or requires an emergency response. • Stop the source of the leak or spill. • Warn others of possible hazards if necessary. • Contain the spill. • Follow the instructions specified on the SDS and guidance from your Emergency Action Plan to safely clean up the spill using personal protective gear if necessary.

18. Spill Response • Dispose of the waste properly. • Don’t forget to notify your supervisor and regulatory agencies if necessary. • Write up a summary of the events that occurred.

19. Spill Response Liquid spills: • Use absorbent materials or mop up small liquid spills. Keep kits labeled “gas/solvent” and “oil” on hand. • Do not hose the spill to a storm drain. • Absorbents used to pick up hazardous materials may be considered hazardous waste, so be careful how you dispose of this material.

20. Spill Response Dry material spills: • Cover a powder spill with plastic sheeting to keep it from blowing until the spill can be cleaned up. • Do not hose the spill to a storm drain. • If usable, place the spilled material back in the original container or one properly marked. • If you are unsure of the proper procedure for disposal of spilled material that cannot be used, call your waste handler, consultant or DEQ.

21. Understanding Hazardous Waste Regulations • There are three programs under RCRA: • Solid Waste Program (Subtitle D) – this program regulates nonhazardous solid waste. • Hazardous Waste Program (Subtitle C) – this program regulates hazardous waste from the point of generation through disposal. The “cradle to grave” regulations. • Underground Storage Tank Program (UST) – this program regulates underground storage tanks containing hazardous substances and petroleum products.

22. Understanding Hazardous Waste Regulations • Under RCRA, companies and facilities can be classified as a generator, transporter, and/or a treatment, storage and disposal (TSD) facility. • Generators of hazardous waste fall into one of the following three categories based on the amount of hazardous waste they create. Your record keeping and compliance requirements will depend upon which category your facility is placed in.

23. Understanding Hazardous Waste Regulations Conditionally Exempt (CE) – produce less than 220 lbs of hazardous waste and less than 2.2 lbs of acutely hazardous waste per month. Exempt from many regulations, however they are required to determine whether their waste is hazardous, notify appropriate state or local agencies and ship it by an authorized transporter to a permitted facility for disposal. No permit required.

24. Understanding Hazardous Waste Regulations • Small Quantity Generator (SQG) – produces between 220 and 2,200 lbs of hazardous waste, but less than 2.2 lbs of acutely hazardous waste per month. SQGs need a permit and are required to keep more records than CE facilities.

25. Understanding Hazardous Waste Regulations • Large Quantity Generator (LQG) – produce more than 2,200 lbs of hazardous waste per month or more than 2.2 lbs of acutely hazardous waste per month. LQGs need a permit and are required to comply with extensive rules and regulations.

26. Understanding Hazardous Waste Regulations • There are regulations governing how much hazardous waste a generator can store, how it can be stored and how long a generator can store it. • Therefore, you must keep records showing dates, quantities, locations, containers and types of waste. • Know what regulations pertain to your facility and maintain records for at least 3 years.

27. Defining Hazardous • Hazardous by definition are the materials listed in one of the four lists published in 40 CFR Part 261. • Hazardous by characteristic is a material that exhibits an ignitable (D001), corrosive (D002), reactive (D003) or toxic (D004) property. Knowledge of product or testing can determine this criteria. • A material generated by the treatment of hazardous waste or mixed with hazardous waste. (Mixing Rule)

28. Defining a Generator • There is a difference between a hazardous chemical and a hazardous waste. • A hazardous chemical is a substance with dangerous properties (may produce fire, explosion, cancer, dermatitis, etc.), but still has value. • A hazardous waste is an unwanted or undesired material left over after the completion of a process. A substance or material with no inherent value or usefulness, or a substance or material discarded despite its inherent value or usefulness.

29. Defining a Generator • Acutely hazardous waste is a special EPA classification of waste fatal to humans in low doses. • Recycle to minimize your hazardous waste disposal requirements.

30. Defining a Generator • How do you stay in compliance and out of trouble? • Learn which regulations affect you. • Obtain the proper permits. • Work courteously with your regulatory agencies.

31. Used Oil • EPA does not regulate used oil as a hazardous waste if it is being recycled or burned for energy recovery. Instead, used oil handlers must follow federal standards found in 40 CFR Part 279. • Used oil generators are businesses that handle used oil through commercial or industrial operations or the maintenance of vehicles. • If used oil is not recycled, the generator must determine if it is a hazardous waste prior to disposal.

32. Used Oil • EPA does require used oil generators to abide by good “management standards.” These requirements cover: • Container types and labels • Leaks, spills and cleanups • Records and documentation Used oil mixed with a hazardous material (ex: gas, solvents) becomes a hazardous waste! • RCRA Hotline for recycling used oil and oil filters: 1-800-424-9346

33. Used Filters • Recycle properly drained used oil filters if possible. Used oil recycling centers will frequently accept used oil filters as well. • Some landfills do not accept used oil filters. If recycling as scrap metal is not an option, check with your local trash collection service and see if it is acceptable to dispose of them with your nonhazardous solid waste.

34. Used Filters • Used oil filters are considered nonhazardous waste if no free flowing used oil is present. • Terne-plated oil filters (new or used) are hazardous because of the lead and tin they contain. • Used fuel filters can be drained and then tested to determine if they are hazardous.

35. Other Used Oils • EPA defines used oil as any oil that has been 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. • These materials are not considered hazardous waste if recycled. If they are mixed with a hazardous waste or sent to a landfill for disposal, they are considered a hazardous waste.

36. Other Used Oils • Other materials treated as used oil are: • Shop rags soaked with used oil • Transmission fluid • Used brake fluid • Compressor oils • Industrial hydraulic fluid • Metal fluids and oils (cutting oil)

37. Not Considered Used Oil • EPA does not consider the following used oils: • Virgin fuel oil recovered from a spill cleanup or other oil wastes that have not actually been used • Products such as antifreeze and kerosene • Vegetable and animal oil, even when used as a lubricant • Petroleum distillates used as solvents or cleaning agents

38. Used Antifreeze • Waste antifreeze should be recycled either on-site, by a mobile recycling service or off-site. Antifreeze is not considered a hazardous waste if it is recycled. • If waste antifreeze is not recycled, knowledge of process or a Toxic Characteristics Leaching Procedure (TCLP) will have to be performed to determine the potential hazards before disposal.

39. Used Antifreeze • If the test results reveal elevated levels of: • Solvents • Metals (primarily lead, cadmium, chromium) • A pH greater than 12.5 s.u. • Or hazardous materials mixed with the antifreeze The waste antifreeze will be declared hazardous.

40. Used Solvents • Used solvents will be considered hazardous if the flashpoint (temp. the liquid will ignite) is less than 140°F. • Other used solvents may be declared a listed or characteristic (toxic) hazardous waste. • Do not mix these with other wastes. To minimize waste, don’t purchase or use more than you really need and recycle as much as possible.

41. Paint and Coatings • Paints and coatings are considered hazardous when: • Flashpoint is under 140°F • They contain elevated levels of certain metals (TCLP metals) • Their base solvents are hazardous To minimize waste, only purchase what you need and donate any extra paint to someone that can use it.

42. Used Rags and Absorbents • Used shop towels that are laundered are not considered a solid waste and therefore, are not a hazardous waste. • What should you do with rags and other absorbents used to clean up spills and leaks? • A good “rule-of thumb” is to manage the rag or absorbent like the material it was used to clean up.

43. Used Rags and Absorbents • After a used oil cleanup, remove as much of the free-flowing oil as possible from the rags or absorbents and then manage the oil as you would have before it spilled. • Once the free-flowing used oil has been removed from these materials, the rags and absorbents are not considered used oil (unless burned for energy recovery) and may be managed as solid waste as long as they do not exhibit a hazardous waste characteristic.

44. Used Rags and Absorbents • Rags and absorbents contaminated with hazardous materials (solvents, antifreeze, paints, gas, etc.) and intended for disposal will likely be considered hazardous waste unless recycled. • If the rag or absorbent was used to clean up a listed hazardous waste or exhibits the properties of a characteristic hazardous material, it will be considered hazardous waste.

45. Batteries • Old batteries may be considered a hazardous waste, depending upon the type of battery. Recycle and exchange old batteries for new ones whenever possible. • Batteries should be stored indoors or protected from the weather with secondary containment capable of containing any battery acid leaks.

46. Tires • Used tires are not considered hazardous waste. • Recycle used tires (retread, sell, shred and reuse for asphalt or other products) whenever possible. • Disposal in a permitted landfill, if permissible, should be a last resort.

47. Transporting Hazardous Waste • A hazardous waste manifest must accompany all hazardous waste that is shipped off site. A manifest is a multipart form designed to track hazardous waste from the time it leaves the generation site until it arrives at the Treatment/Storage, Disposal Facility (TSDF). • This form must be signed by the transporters and receiving facility and then returned to the generator.

48. Helpful Agencies • For hazardous waste questions in Oklahoma, call 405-702-9128 and ask for Hazardous Waste Compliance • Oklahoma Public Employee Occupation, Safety & Health: 405-528-1500 x 226 • EPA Superfund hotline number is: 1-800-424-9346

49. Helpful Agencies • Additional information on Solid & Hazardous waste can be found at www.epa.gov/osw • DOT Hazardous Materials Information Line: 202-366-4488

50. Helpful Agencies • For reportable oil and chemical spills, call the National Response Center at: 800-424-8802 • To talk to the ODEQ Pollution Prevention Coordinator, call: 800-869-1400 or 405-702-9128