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SURVIVING A CUPA INSPECTION 2008

SURVIVING A CUPA INSPECTION 2008. MFASC CONTINUING EDUCATION MOORE COMPLIANCE & TRAINING, INC. HAZARDOUS MATERIALS MANAGEMENT PROGRAM. UNIFIED PROGRAM FACILITY PERMIT Current CUPA permit is on-site. Avoid late fees. Renewal information is mailed out two months before the fees are due.

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SURVIVING A CUPA INSPECTION 2008

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  1. SURVIVING A CUPA INSPECTION2008 MFASC CONTINUING EDUCATION MOORE COMPLIANCE & TRAINING, INC.

  2. HAZARDOUS MATERIALS MANAGEMENT PROGRAM • UNIFIED PROGRAM FACILITY PERMIT • Current CUPA permit is on-site. • Avoid late fees. Renewal information is mailed out two months before the fees are due.

  3. HAZARDOUS MATERIALS MANAGEMENT PROGRAM • RECORD KEEPING • Hazardous Materials Business Plan • Consolidated Contingency Plan • Hazardous Material Chemical Inventory • Current and up to date? • Emergency Coordinator Information • Current and up to date?

  4. HAZARDOUS MATERIALS MANAGEMENT PROGRAM • RELEASE REPORTING • Immediate Notification • Procedures for mitigation • Evacuation plans and procedures • Employee training plan

  5. HAZARDOUS WASTE GENERATOR REQUIREMENTS • HAZARDOUS WASTE DETERMINATION • Waste stream characteristic.

  6. HAZARDOUS WASTE GENERATOR REQUIREMENTS • IDENTIFICATION NUMBER • EPA ID Number- Do you have the correct type of number (prefix)? • CAL • CAD • CAR

  7. HAZARDOUS WASTE GENERATOR REQUIREMENTS • DISPOSAL, TREATMENT & TRANSPORTATION • Hazardous waste going to a “permitted” facility? • Being treated onsite? • Got a Tiered Permit? • Hazardous waste being transported by a registered hazardous waste transporter?

  8. HAZARDOUS WASTE GENERATOR REQUIREMENTS • STORAGE • 90 days for on-site hazardous waste in tanks or containers (LQG). • 180/270 days for on-site hazardous waste in tanks or containers. (SQG) • 1 year or 55 gallons for satellite accumulation.

  9. HAZARDOUS WASTE GENERATOR REQUIREMENTS • STORAGE • Discontinue storage of hazardous waste in anything other than containers, tanks, drip pads, or containment buildings.

  10. HAZARDOUS WASTE GENERATOR REQUIREMENTS • USE AND MANAGEMENT OF CONTAINERS • Leaking or in poor condition. • Incompatible storage. • Containers kept closed. • Handling of containers. • Weekly inspections. • Store hazardous materials in undamaged containers or manage as hazardous waste.

  11. HAZARDOUS WASTE GENERATOR REQUIREMENTS • CONTAMINATED CONTAINERS • Mark containers or inner liners greater than 5 gallons with: The Date Emptied and suggest the word “EMPTY”. • Manage within 1 year. • Put into use • Recycle/reclaim • Sent off as hazardous waste

  12. HAZARDOUS WASTE GENERATOR REQUIREMENTS • LABELING AND MARKING REQUIREMENTS • Each container and tank of hazardous waste: • Accumulation start date. (First drop) • “Hazardous Waste” • Contents, physical state, hazardous properties, generator name and address.

  13. HAZARDOUS WASTE GENERATOR REQUIREMENTS • LABELING AND MARKING REQUIREMENTS • Label hazardous materials container properly or handle as a hazardous waste.

  14. HAZARDOUS WASTE GENERATOR REQUIREMENTS • TANKS • Integrity assessment certification. • Secondary containment. • Ignitable or reactive wastes. • Daily tank inspections. • Closure.

  15. HAZARDOUS WASTE GENERATOR REQUIREMENTS • PREPAREDNESS & PREVENTION • Maintain site to minimize possibility of fire, explosion, unplanned release of hazardous waste to environment. • Equip site with: • Internal and external communication system. • Fire, spill control and/or decon equipment and test them. • Maintain adequate aisle space. • Familiarize local response agencies.

  16. HAZARDOUS WASTE GENERATOR REQUIREMENTS • DOCUMENT REVIEW • Hazardous Waste Manifest System • Mail legible copy to DTSC within 30 days. • Maintain records for at least 3 years.

  17. HAZARDOUS WASTE GENERATOR REQUIREMENTS • LAND DISPOSAL (LDR) RESTRICTIONS • Maintain records of all LDR paper work.

  18. HAZARDOUS WASTE GENERATOR REQUIREMENTS • RECORDKEEPING & REPORTING • Retain waste analysis test records for 3 years. • Retain a copy of Biennial Report. • Submit a Biennial Report by 3/1 (every even numbered years) for odd numbered years to DTSC. • Report release incidents to CUPA.

  19. HAZARDOUS WASTE GENERATOR REQUIREMENTS • CONTINGENCY PLAN & EMERGENCY PROCEDURES • Maintain a contingency plan. • Implement contingency plan when needed. • Describe actions needed to respond to an emergency. • Identify emergency coordinators.

  20. HAZARDOUS WASTE GENERATOR REQUIREMENTS • CONTINGENCY PLAN: • Evacuation plan. • CUPA & OES telephone numbers. • List of emergency equipment and location. • Copy submitted to CUPA. • Maintain/updated as needed. • Maintain emergency coordinator on site or on call at all times.

  21. HAZARDOUS WASTE GENERATOR REQUIREMENTS • PERSONNEL TRAINING • Training program directed by a qualified hazardous waste person. • Provide training program in hazardous waste procedures. • Ensure all personnel are trained . • Provide annual refresher training. • Maintain training records for 3 years.

  22. HAZARDOUS WASTE GENERATOR REQUIREMENTS • SOURCE REDUCTION • Completed SB14 plan available. • What make up a completed plan? • Required reports filed with DTSC.

  23. ON-SITE HAZARDOUS WASTE TREATMENT PROGRAM • FACILITY NOTIFICATION REQUIREMENTS • Submit “Onsite Hazardous Waste Treatment Form” • Submit “Onsite Hazardous Waste Treatment Facility Information Plan”. • Plot Plan. • Amended notification within 30 days. • Notify CUPA of closure 15 days before.

  24. ON-SITE HAZARDOUS WASTE TREATMENT PROGRAM • GENERAL REQUIREMENTS (PBR, CA & CE) • Manage hazardous waste per regulations. • Treat only wastes generated on-site. • Restrict type and volume per permit level. Concentration of hazardous waste. • Inspection schedule – 3 years. • Pretreatment standards. • Proper closure.

  25. ON-SITE HAZARDOUS WASTE TREATMENT PROGRAM • CA AND PBR • Control all entry points and post warning signs. • Provide containment system. • Maintain containment system. • Annual hazardous waste minimization certification. • Phase I environmental assessment.

  26. ON-SITE HAZARDOUS WASTE TREATMENT PROGRAM • CA AND PBR • Financial assurance for closure. • Annual adjustment of closure cost. • Submit information about releases.

  27. ON-SITE HAZARDOUS WASTE TREATMENT PROGRAM • PBR • Mark exterior of each treatment unit. • Develop/maintain Waste Analysis Plan. • Repeat analysis to stay up to date. • Maintain Operating Records. • Submit annual report when requested. • Maintain Written Closure Plan.

  28. ON-SITE HAZARDOUS WASTE TREATMENT PROGRAM • RECYCLING EXEMPTION AND EXCLUSION REQUIREMENTS • Document claim for exemptions or exclusion for recycling. • Label containers “Excluded Recyclable Materials”. • Report to CUPA every 2 years status of recycling.

  29. ON-SITE HAZARDOUS WASTE TREATMENT PROGRAM • Treat only hazardous waste which are generated onsite. • Restrict hazardous waste treatment to those wastes, volumes and processes authorized for the reported treatment tier. • Treatment of Aqueous Cyanide Waste is now part of PBR. “Consent Decree” is now history. • Manage residual properly.

  30. ON-SITE HAZARDOUS WASTE TREATMENT PROGRAM • Prepare and maintain written operating instructions. • Maintain a written operating log of: • Dates • Amounts • Hazardous constituents • Types of waste treated • Residual management

  31. ON-SITE HAZARDOUS WASTE TREATMENT PROGRAM • Maintain a written inspection schedule. • Records shall include: • Date & time of inspection • Name of inspector • Notation of observations made • Date and nature of any repairs or other actions • Records shall be maintained for three years.

  32. ON-SITE HAZARDOUS WASTE TREATMENT PROGRAM • Maintain adequate records to demonstrate that the facility is in compliance will all pretreatment standards and applicable industrial waste discharge requirements issued by the POTW. • Upon closure, remove or decon any residue, equipment or soil.

  33. ON-SITE HAZARDOUS WASTE TREATMENT PROGRAM Notify your local CUPA of any changes in your fixed treatment unit within 30 days of changes.

  34. ON-SITE HAZARDOUS WASTE TREATMENT PROGRAM • CA and PBR • Control all entry points to waste treatment area at the facility and post a sign at each entrance: • “Danger -- Hazardous Waste Area -- Unauthorized Personnel Keep Out” • Post a “No Smoking” sign where there is a hazard from ignitable or reactive waste.

  35. ON-SITE HAZARDOUS WASTE TREATMENT PROGRAM • CA and PBR …..continued • Provide containment systems for hazardous waste treatment, transfer and storage areas. • Retain onsite the written assessment, certifies by a registered professional engineer, that the secondary containment systems has sufficient structural integrity.

  36. ON-SITE HAZARDOUS WASTE TREATMENT PROGRAM • CA and PBR…..continued • Maintain the containment system. • Maintain an annual hazardous minimization certification. • Provide financial assurance for closure. • Adjust the closure cost estimate for inflation by March of each year.

  37. ON-SITE HAZARDOUS WASTE TREATMENT PROGRAM • CA and PBR ….. Continued • Conduct a Phase I environmental assessment. • Submit updated information, subsequent to the submission of the Phase I assessment. • Maintain documents of any environmental investigation, judgments, etc.

  38. ON-SITE HAZARDOUS WASTE TREATMENT PROGRAM • PBR • Permanently mark the exterior of each treatment unit with the name of the person who owns or operates the unit, facility ID number and serial number. • Develop and maintain onsite a written waste analysis plan for treatment of hazardous waste.

  39. ON-SITE HAZARDOUS WASTE TREATMENT PROGRAM • PBR….Waste Analysis Plan • The waste analysis plan shall specify: • Detailed chemical and physical analysis of a representative sample of the waste to be treated. • Parameters for each hazardous waste to be analyzed. • Test methods which will be used. • Sampling and sampling management methods to be used. • Frequency of analysis and reanalysis of hazardous waste.

  40. ON-SITE HAZARDOUS WASTE TREATMENT PROGRAM • PBR….Operating Records • Prepare and maintain an Operating Record with the following: • Description, quantity, methods and dates of all hazardous waste treated. • Results of waste analysis. • Summary reports and details of all incidents that require implementing the Contingency Plan.

  41. ON-SITE HAZARDOUS WASTE TREATMENT PROGRAM • PBR…continued • Prepare and submit an annual report to DTSC and/or local CUPA when requested. • Prepare and maintain a detailed closure plan for each unit, including steps needed to decontaminate each unit and a schedule for the process.

  42. ON-SITE HAZARDOUS WASTE TREATMENT PROGRAM • Secondary containment area to be dry. • Aqueous Cyanide Waste Treatment • Consent Decree for Cyanide treatment is no more. • Secondary Containment & System Certification by PE. • CUPA now has a guidance document for this certification. • All piping to treatment area is covered.

  43. And the crowd went wild…… Permit by rule for treatment of aqueous waste containing cyanides

  44. Cyanide-Containing Wastes • Aqueous wastes generated by the rinsing of parts, racks, etc. • Aqueous waste from RO units. • Aqueous waste generated from rinsing of equipment. • Aqueous wastes from on-site recycling – rinsing of anode bags – empty containers. • Spent process solution.

  45. Authorized Treatment Processes • Oxidation with Hypochlorite. • Oxidation with Peroxide or Ozone. • Alkaline Chlorination. • Electrochemical Oxidation. • Ion Exchange. OR • Reverse Osmosis.

  46. Reduction of Cyanide Wastes • As Specified: • Holding time between tanks • Drag out tanks, dead rinses, countercurrent rinse tanks, etc. • At lease every four years review use of cyanide and evaluate if there are any non-cyanide solutions available. • May be part of the SB 14 report.

  47. Employee Training • Initial & Annual Training: • Reduce drag-out. • Minimize contamination. • Extend bath life. • Minimization of chemical spills and splashes. • Response to chemical spills.

  48. Non-aqueous Cyanide Wastes Thou shall not treat non-aqueous hazardous waste containing cyanide.

  49. Metal Recovery • Process solutions may be treated to reclaim metals by electrowinning.

  50. Spent Process Solutions • May be treated by slow addition to the aqueous waste streams already mentioned. • Concentration shall not exceed 5000 ppm of total cyanide.

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