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Hazardous Waste Management New England Marina Meeting March 30, 2006

Hazardous Waste Management New England Marina Meeting March 30, 2006. U.S. Environmental Protection Agency (EPA) Region 1 New England. Where to look for Guidance. EPA Office of Compliance Sector Notebook Project.

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Hazardous Waste Management New England Marina Meeting March 30, 2006

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  1. Hazardous Waste Management New England Marina MeetingMarch 30, 2006 U.S. Environmental Protection Agency (EPA) Region 1 New England

  2. Where to look for Guidance EPA Office of Compliance Sector Notebook Project “Profile of the Water Transportation Industry”, September 1997, EPA/310-R-97-003 “Profile of the Shipbuilding and Repair Industry”, November 1997, EPA/310-R-97-008 Shipshape Shores and Waters- A Handbook for Marina Operators and Recreational Boaters, January 2003, EPA-841-B-03-001 www.epa.gov/owow/nps/marinashdbk2003.pdf

  3. RCRA Components Subtitle C - Hazardous Waste Subtitle D - Solid Waste Subtitle I – Underground Storage Tanks Subtitle C – Cradle to Grave Control of Hazardous Wastes

  4. RCRA Subtitle C Goals • protect human health and environment from hazards posed by waste disposal, • To ensure that wastes are managed in a manner that is protective of human health and the environment. • To conserve energy and natural resources via waste recycling and recovery, • To reduce or eliminate the amount of waste generated

  5. Statutory Definition of SolidWaste ….any garbage, refuse, sludge from a waste treatment plant, water supply plant or air pollution control facility, and other discarded material, including solid, liquid, semisolid, or contained gaseous material... SOLID WASTE NEED NOT BE SOLID!

  6. Statutory Definition of Hazardous Waste A “solid waste, or a combination of solid wastes, which because of its quantity, concentration, or physical, chemical, or infectious characteristics may: 1) Cause, or significantly contribute to an increase in mortality or an increase in serious irreversible, or incapacitating reversible, illness or 2) Pose a substantial present or potential hazard to human health or the environment when improperly treated, store transported, or disposed of, or otherwise managed.”

  7. A Solid waste is hazardous if it: • Exhibits any of the characteristics of a hazardous waste • Has been named as a hazardous waste and listed as such in the regulations • Is a mixture containing a listed hazardous waste and a non-hazardous solid waste • Is a waste derived from the treatment, storage, or disposal of a listed waste

  8. Characteristic Hazardous Wastes • Ignitability • Reactivity • Corrosivity • Toxicity (via TCLP)

  9. Three Lists of Hazardous Wastes • Non-specific Source Wastes • Specific Source Wastes • Commercial Chemical Products

  10. IT IS YOUR RESPONSIBILITY !! As the Owner/Operator you must know all the waste streams you generate and which ones are Hazardous Wastes and, therefore, regulated. Do Hazardous Waste Determinations!!

  11. EPA/Federal & State Regulations • citation: 40 CFR Parts 260-299 • authorized states and their regulations [equivalent or more stringent than feds]

  12. HAZARDOUS WASTE DETERMINATIONS • Generator’s responsibility • Process knowledge • Analysis • MSDS • Expiration dates • Variability of waste streams • Cross contamination

  13. Waste Activity Notificationand Generator Classification • Large Quantity >1000Kg (2200#) ……………..…LQG (1 Kg Acutely Toxic Wastes) • Small Quantity 100-1000Kg (220-2200#)………..SQG • Conditionally Exempt SQG <100Kg (220#)…...CESQG Amount Generated =Classification with accumulation limits. [Volume and Time] [There are State Variations- see State Regulations]

  14. Depending on Your Classification, There Are Requirements for….. • Record keeping • Housekeeping • Accumulation Time Limits • Emergency Preparedness Needs • Employee Training

  15. Specific Container Management Requirements for …… Satellite vs. Non-Satellite Storage Areas

  16. Labeling Dating Compatibility Aisle space Open/Closed Containers Condition of containers Ignitable waste special requirements MANAGEMENT REQUIREMENTS in CONTAINER STORAGE AREAS

  17. Satellite Storage….. • At or near point of generation • Under the control of the operator of the process • Less than 55-gallons of wastes – total • Labeled “Hazardous Waste” or other words to describe contents • Keep containers closed, except when adding or removing

  18. (Depending on Classification) CONTAINER STORAGE AREA INSPECTIONS The owner or operator must inspect areas where containers are stored, at least weekly, looking for leaks and for deterioration caused by corrosion or other factors.

  19. Manifesting Wastes Requirements Key to Cradle to Grave Management

  20. Land Disposal Restriction Notifications • Protect human health & environment • Minimize reliance on land disposal • Determine if wastes generated are restricted from land disposal. • Determine the appropriate treatability group (if any) for restricted wastes. • Determine if wastes meet treatment standards as generated.

  21. HAZARDOUS WASTE TRAINING • Initial training • Annual refresher training • Documentation of training program and employee training records • Relevant to job duties performed • Training program led by qualified staff • document Job titles and Job descriptions RCRA Training is not OSHA or Emergency Response training. RCRA Training develops understanding of appropriate hazardous waste management practices.

  22. PREPAREDNESS AND PREVENTION Facilities must be maintained and operated to minimize the possibility of a fire, explosion or release of hazardous waste or hazardous constituents.

  23. CONTINGENCY PLAN • must be designed to minimize hazards to human health and the environment from fires, explosions, or release of hazardous waste or hazardous waste constituents. • must be carried out immediately. • describe detailed response actions • provide for arrangements with locals • designate Emergency Coordinator and alternates • identify emergency equipment • identify evacuation plans

  24. PREPAREDNESS AND PREVENTION • Alarm system • Communication devices • Extinguishers • Adequate water supply • Adequate aisle space • In-place arrangements with locals [fire, police, hospitals]

  25. Universal wastes are widely generated and widely recycled hazardous wastes. Management standards for these wastes are reduced to facilitate their recycling. UNIVERSAL WASTE

  26. Types of UNIVERSAL WASTE • Batteries • Mercury containing thermostats • Hazardous waste lamps • state specific UWs

  27. Universal Waste Requirements.. • Containerized • Labeled to describe content • Dating • Training • Record keeping

  28. RCRA Compliance Evaluation Inspection Outline • Unannounced • Most are multi-day • Physical inspection of waste storage, generation points and processes, tour of operations and property

  29. Inspections - continued Opening Conferencethe inspector may ask • How many employees and shifts • What is your generator status • For explanation of processes, description of wastes and where generated • Where wastes are stored- satellite and 90/180 day • Inspector will explain how the physical inspection will proceed • Inspector will request availability of documents for records review

  30. Inspections (continued)… • Documents for Record Reviews includes but is not limited to: • training documents, contingency plans, shipping documents and LDRs, waste determination documentation, inspection logs, Biennial Reports, emergency preparedness information, import/export documentation

  31. Inspections (continued) Close-Out Conference • Ask for additional information. • Review areas of concern from walk- through and record review. • Explain potential follow up. • Give facility representatives an opportunity to comment or ask questions.

  32. Post-Inspection • Information Requests • Possible Case Development Inspections • Inspection Report • Several months possible

  33. Common Marina Wastes • Paint and paint related wastes • Aerosol cans • Chemical stripping wastes • Abrasive stripping wastes • Equipment cleaning wastes • Machine Shop wastes • Engine Repair wastes • Waste Oils, gear and lube oils

  34. Common Marina Wastes • Transmission fluid • Waste fuel • Welding wastes • Fiberglass fabrication (solvents, resins, gelcoat wastes) • Leftover raw materials/ Off-spec products • Acids and alkalis • Metal finishing wastes

  35. Common Marina Wastes • Pb/acid batteries • Bilge water/bilge sludges • Engine test tank waters • Parts washer waste • Rags • Adhesive wastes

  36. Common Marina Wastes • Electronics wastes • Pesticides and herbicides • Compressed gas cylinders • Filters- fuel, oil, paint booth • Antifreeze (benzene) • Dust collection system residues • SEE LAST PAGE OF HANDOUT FOR MORE

  37. Common Areas of Observed Violations • Hazardous Waste Determinations • Main Hazardous Waste Accumulation Area and/or Satellite Accumulation Area Container Mismanagement • Open Containers • Aisle space • Secondary Containment • Unmarked/Unlabeled Containers • Incompatible Storage • No or Inadequate Land Disposal Restriction (LDR) Notices

  38. Common Areas of Observed Violations (continued) • No or incomplete Hazardous Waste Manifests • Inadequate Emergency Preparedness and Inadequate/Outdated Contingency Plan • No or Inadequate Hazardous Waste Training • No or inadequate In-house Inspections • Storage > 180 Days, >90 Days w/o Permit

  39. HW Determination Violations What we find... • Mischaracterized or uncharacterized wastes; or • Materials that are unused and pending disposal not characterized What we want... • All wastes/materials characterized as soon as they are generated or when they are not going to be used

  40. HW Determination Violations (continued) Because... Certain wastes have adverse affect on human health and/or the environment - that's why they're regulated. THE PERSON WHO GENERATES THE WASTE IS RESPONSIBLE FOR KNOWING WHAT IT IS!!!

  41. Open Containers Violations What we find... • Containers with no cover, no bung, or open funnel in bung What we want... • All containers of hazardous waste closed unless materials are being added or removed Because... • Materials can be easily spilled from an open container. Volatile materials may escape.

  42. Unmarked/Unlabeled Container Violations What we find... • Hazardous waste containers that have missing information/no information or are not dated What we want... • Containers with labels that say the words "Hazardous Waste" and a description of the waste and the date when the waste started to accumulate (and sometimes more).

  43. Unmarked/Unlabeled Containers (continued) Because... • A properly labeled container assures that everyone, including workers and emergency responders, knows that there is a hazardous waste in the container and exactly what the waste is. Helps avoid mismanagement.

  44. Unmarked/Unlabeled Containers (continued) • Has caused wastes to be commingled • Results in no one knowing what the container holds, for example: -person who knew has left the company -person who knows is on vacation when inspector arrives • Can increase need for laboratory waste stream analysis for waste determinations

  45. Satellite Accumulation Violations What we find... • Hazardous waste drums being stored far from the place where the wastes are generated • ...not under anyone's control • ...more than 55-gallons What we want... • At or near the point of generation and under the control of the operator, no more than 55-gallons, and container meets management requirements

  46. Satellite Accumulation Violations (continued) Because • We don't want people walking long distances with uncontrolled quantities of hazardous waste • We want someone watching over these containers. • We don't want a lot of material hanging around.

  47. Incompatible Waste Storage Violations What we find... • Incompatible materials stored next to each other, or stacked on top on one another. What we want... • Incompatible materials separated by a berm, dike, wall or other physical barrier. Because... • KABOOM!!!

  48. Hazardous Waste Training Violations • Common Issue! • Annual training conducted once and lapses • Training is not relevant to duties performed • Documentation is not maintained • No plan on who should be trained and what they should be trained on • Job descriptions not available or…

  49. Hazardous Waste Training Violations (continued) • Available, but no longer applicable for employee - For example: - personnel have rotated and job description no longer fits, or - job duties have changed and no longer match the job description Note: A bad training program will lead to poor waste management!

  50. LDR Notices/Copies Violations What we find… • Notices not completed at all or incomplete • Copies are not maintained or available at the facility What we want… • Copies of all fully completed notices maintained for 5 years. Because… • It is important that all parties that manage the hazardous waste know that it must be treated before disposal.

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