Hazardous Waste Regulatory Training

1. Hazardous Waste Regulatory Training ACUITY BRANDS ATLANTA, GA Presented by: HERITAGE GROUP SAFETY

2. RCRA • More than 40 million tons of hazardous waste are generated each year. • Most comes from large manufacturers, refineries, factories and producers. • Some comes from printers, laundries, photo labs, gas stations and other small facilities.

3. Managing Hazardous Waste • Treating, storing and getting rid of hazardous waste means different things to different people. • Owners of businesses-comply with Federal law. • Government official-ensure no harm to people or property. • Concerned citizen-want assurance that everyone handling HW knows what to do.

4. EPA and RCRA • Resource Conservation Recovery Act was established in 1976. • EPA has been developing specific requirements for handling HW to protect human health and the environment. • EPA gave us a Christmas tree! • OSHA, DOT and Coast Guard are also involved.

5. What Was It Like Before RCRA? • Rivers, lakes and streams polluted. • News stories everyday concerning random dumping.

6. The Main Players • Generators-companies that produce HW. • Transporters-move it from one place to another. • Waste Managers-treat, store and ultimately get rid of HW.

7. What Is Hazardous Waste? • Any solid, liquid or gas waste, which if not properly discarded would cause harm to human health or the environment. • Characteristics of HW: • Ignitable • Corrosive • Reactive • Toxic

8. Where does it come from? • EPA estimates that approximately 90-95% of HW is generated by large companies. • The other 5-10% is generated by small companies-known as small quantity generators or SQG’s.

9. Listed Wastes • Non-Specific Sources-”generics”- solvents, electroplating rinses, waste-water treatment sludges and other metal treating sludges. • Specific Sources-from specific industries-paint, lead, ink, petroleum, pesticides,etc. • Discarded commercial products-or not used for their intended purpose.

10. GENERATOR REQUIREMENTS • Bear principle responsibility for their waste and: • Determine hazardability. • Obtain EPA ID number. • Use HW Manifest. • Proper packaging. • Proper labeling. • Ensure proper disposal.

11. GENERATORS • Can treat and dispose on their site-96%. • Hire off-site managers-4%. • Must ensure companies have EPA authorization-waste managers and transporter.

12. Use of the Uniform Manifest • EPA form 870-22 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.

13. 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.

14. Generator Must be Notified • In 35 days or call to find if where the waste is. • In 45 days or call the EPA.

15. Packaging and Labeling • HW must be properly packaged to ensure there is no significant release to the environment. Meet DOT requirements. • Containers must be properly labeled and placarded to identify what is being transported, where it came from and where it is going, and provide special handling instructions.

16. Storing Hazardous Waste • Generators of more than 2200 lbs.. In one month may accumulate and store any amount up to 90 days. • Storage requirements apply.

17. Storing, continued • Generators of 220-2200 pounds may store up to 2200 pounds on site for 180 days or 270 days if the waste is being shipped more than 270 miles.

18. TRANSPORTERS • Responsible for spills during transport. Must ensure wastes do not spread from the scene, notifying proper authorities and arranging for clean-up. • Must have EPA ID number. • Comply with manifest requirements. • Deliver the waste. • Ensure proper documentation.

19. Managing Hazardous Wastes • TSD’s are responsible for treating, storing and getting rid of the waste per Federal requirements. • General requirements” • EPA ID number. • Waste Analysis (waste analysis plan). • Permit to construct or operate. • Emergency Planning (contingency plan)

20. TSD’s continued • Manifest and Record Keeping. • Closure requirements.

21. Storage and Disposal • Tanks-above or under ground. • Concrete, Steel or Plastic. • Designed so it will not overflow. • If waste is fed continuously-it must have equipment to control flow and alarm for overflow. • Inspected regularly.

22. Land Disposal • Surface Impoundments • Landfills • Waste Piles • Land Treatment Units • Injection Wells

23. Incineration • Burning hazardous waste at high temperatures. • Must be designed, constructed and maintained so that it can remove all (99.99%) of the hazardous elements of the waste it is burning.

24. Liability Coverage • TSD’s - $ 1-2 million • Landfills - $ 3-6 million • Transporters - $ 5-7 million

25. Basic Requirements of Hazardous Waste Generators

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

27. 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

28. 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.

29. 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

30. 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

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

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

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

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

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

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

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

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

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

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

41. 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)

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

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

44. 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.

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

46. Waste Material • Is the Waste Excluded From Definition of Solid Waste (40 CFR 261.4(a) or by Reuse or Recycling)?

47. Solid Waste • Is the Waste Excluded from Definition of Hazardous Waste (40 CFR 261.4(b))?

48. 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)

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

50. 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