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US EPA and US DOT Hazardous Waste Management Training

US EPA and US DOT Hazardous Waste Management Training. Sam Tinsley National Compliance Manager IG America. 2010. Two Businesses. ONE YOU CHOSE: Hot-Dip Galvanizing ONE YOU DIDN’T CHOOSE: Regulatory Compliance

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US EPA and US DOT Hazardous Waste Management Training

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  1. US EPA and US DOT Hazardous Waste Management Training Sam Tinsley National Compliance Manager IG America 2010

  2. Two Businesses • ONE YOU CHOSE: Hot-Dip Galvanizing • ONE YOU DIDN’T CHOOSE: Regulatory Compliance • Obeying the laws and regulations of Federal, State and Local agencies in the United States.

  3. Federal ProgramsThat Govern Hazards • EPA – Environmental Protection Agency Protection of human health and the environment • RCRA - Resource Conservation and Recovery Act Hazardous waste management • CERCLA - Comprehensive Environmental Response, Compensation and Liability Act (Super Fund): Hazardous material or waste that has been released into the environment

  4. Federal ProgramsThat Govern Hazards • OSHA – Occupational Safety and Health Administration • Hazards in the Workplace, • Hazardous Chemicals and Waste • Job Safety Hazard Analysis • Hazard Communication • MSDS • Hazardous Material Checklist • MSDS Review • Hazardous Chemical Worksheet

  5. Federal ProgramsThat Govern Hazards • DOT – Department of Transportation • Hazardous Material • Hazardous Chemicals and Hazardous Wastes that are shipped on highways, air or water in the United States • Staging and loading HM onto trucks for shipment

  6. State ProgramsThat Govern Hazardous Wastes • Alabama - ADEM • St. Clair County • Florida - DEP • Hillsborough County • Miami/Dade - DERM • South Carolina - DHEC • Lexington County • Virginia - VDEQ • City of Petersburg

  7. Serious Business • Civil and Criminal Penalties • $ 37,500 per day minimum • $ 500,000 per day maximum • 1-5 years in prison

  8. Who Is Responsible for Hazardous Waste and Must Be Trained • General Manager • Operations Manager • Compliance Specialist • Forklift Operator • Anyone who has anything to do with hazardous waste in an IG plant: • Pickler – If he assists in the pump out • Purchasing – Orders Hazardous Waste Containers or other Hazardous Waste Supplies • Person who signs or files the hazardous waste manifests • Operators overseeing Satellite Accumulation

  9. Hazardous Waste Training Requirements • Annual US EPA and US DOT Hazardous Waste Training – Provided by the NCM • US DOT Training – Self-paced software program on one of your computers • General Awareness Training – Scheduled in the IG Safety Training annual calendar • US DOT Security Plan – Scheduled in the IG Safety Training annual calendar

  10. You Must Also Provide DOT Training for Hazardous Waste Employees • Since you are shipping hazardous waste on US roads and highways you must also have US DOT training which must include: • Infotrac DOT Training – Computerized training that is good for three years • DOT Security Plan Training – Annual and the training is included in the monthly Safety Meeting training schedule

  11. Who Is Responsible for Hazardous Waste and Must Be DOT Trained All those who work directly with preparing Hazardous Waste for shipment: • Operations Manager • Compliance Specialist • Forklift Operator • The Person(s) who signs or files the hazardous waste manifests

  12. US EPA/RCRA Working Definitions • WASTE – Anything that has no further use to the company • GENERATOR – Anyone or company that creates a waste or causes a waste to be subject to regulation • SHIPPER – Anyone or company that prepares or offers hazardous waste for shipment • TRANSPORTER – Anyone or company that transports hazardous waste over US roads and highways

  13. Is Your “Waste” Regulated by the EPA? • It may not be a “Waste” as defined by the EPA • If your waste is not defined as a waste by the EPA then it is not regulated. • First, is it an EPA-defined “waste”? • Abandoned – Will no longer by used • Recycled but not reclaimed or reused as is • “Waste-like” by EPA (Dioxins, etc.) • Second, if it is a waste, is it an EPA-defined “solid” waste? • Solids, Liquids • Semi-solids, Some gases • Finally, if the answer is “It is an EPA-defined “solid waste” it may or may not be regulated.

  14. Is Your Solid Waste Excluded? • Some solid wastes are “excluded” from regulation (40CFR 261) • Some IG wastes are excluded: Office paper, scrap metal • Baghouse dust • “Sludges” that are sent for recycling. • Even if the sludge is hazardous it is not considered to a waste • They are called “Byproducts” by the EPA

  15. Some Solid Waste is Excluded

  16. Some Solid Waste is Excluded • Spent: Used up, no value • Sludge: Baghouse dust • Byproduct: What we call “sludges” that can be sold or sent to be recycled • Commercial Chemical Product: Unused product • Scrap Metal: Sent for Recycling

  17. Is Your Solid Waste Excluded? • If your waste is not excluded, then it is regulated and you must determine if it is hazardous or not. • That determination has to be made when the waste is first created.

  18. How To Determine If Your Waste Is Hazardous? • If it is a leftover chemical or product that hasn’t been mixed with anything, then… • Check the MSDS for hazardous ingredients • If there are none, then it is non-hazardous • If there are, then it is hazardous • If it is a mixed chemical or if it is from a process solution (caustic, acid, preflux, quench), then… • Send a sample to a local lab for analysis • Ask for pH and RCRA “TCLP-Metals” analysis • Forward results to the NCM and to your Waste Broker or Hauler to develop a Profile • Send a copy of the Profile to the IG NCM (Sam)

  19. TCLP and pH • TCLP = Toxicity Characteristic Leaching Procedure • Simulates what would happen in a landfill over time. • pH less than or equal to 2 is acidic and is hazardous as corrosive. • pH greater or equal to 12.5 is an alkali and is hazardous as corrosive.

  20. Hazardous Waste ID Flowchart 1 2 3 4

  21. Hazardous Waste ID Step-by Step • Is it a “discarded unused product”? • If yes, is it “listed” as a P or U hazard? • “P” List: Acutely Hazardous • “U” List: Toxic • If no, is it “listed” as an F or K hazard? • “F” List: Process waste from a non-specific source of generation • “K” List: Process waste from a specific source of generation • Even if it is not “listed”, does it have any hazardouscharacteristics? • Check for need to use D Codes

  22. Hazardous Waste “D” Codes

  23. If You Do Have Hazardous Waste, There are Different Management, Storage and Shipping Requirements Depending on How Much Hazardous Waste You Create Each Calendar Month • CESQG (ses-kwa-gee) • < 220 lbs of hazardous waste per month • < 2.2 lbs of “acutely” hazardous waste • < 100 lbs of hazardous debris • No EPA ID#, Manifests or LDR’s • SQG – Small Quantity Generator • > 220 lbs but < 2,200 lbs per month • < 2.2 lbs of “acutely” hazardous waste • LQG – Large Quantity Generator • > 2,200 lbs of hazardous waste per month • > 2.2 lbs of “acutely” hazardous waste

  24. Storage Options forLarge Quantity Generators • 90 Day Rule • Point of Generation or Satellite Accumulation • Universal Waste • 180 Day Rule (SQG’s only) • Storage Permit (TSDF’s and LQG’s)

  25. “90 Day” Storage Rule • Store hazardous waste on-site for 90 days without a permit • Waste must be placed in: • Containers • Tanks • Containment Buildings (Not used by IG) • Drip Pads (Not used by IG) • Must have a label on it with: • “Start Date” - When the container is first used to store hazardous waste • The words: “Hazardous Waste”

  26. Hazardous Waste Storage Label If you are using the 90-Day Storage Option May use pre-printed labels, home-made or masking tape

  27. Point-of-Generation or Satellite Accumulation Storage Option • You are permitted to collect up to 55 gallonsof hazardous waste (or 1 quart of acutely hazardous waste) at each or near each “point-of-generation” and it must be under the control of the operator. • Must have a label with the words “Hazardous Waste” or other form of identification on it. • When you collect more than 55 gallons and you have to use a second container,you must… • Label the first container with the date you collected more than 55 gallons, and… • Manage the first container under the 90-day option and move it into your hazardous waste storage area OR ship it off-site within 3 days

  28. Hazardous Waste Storage Label Point of Generation or Satellite * Add the Date to the label on your container after more than 55 gallons of waste has been collected and you need another container.

  29. “Universal” Hazardous Waste • Alternate set of regulations • Covers • Batteries • Pesticides • Devices containing Mercury (Thermostats) • Lamps (Light Bulbs) - May include so-called “green” fluorescents depending on Mercury content. • Marked with “Universal Waste - Lamps” or “Universal Waste - Batteries” (whatever it is) • Accumulate up to 1 year • No hazardous waste manifest • Training for all employees

  30. Hazardous Waste Storage Label Universal Waste May use pre-printed labels, home-made or masking tape

  31. Storing Hazardous Wastein Containers or Tanks • Containers • Good condition • Compatible with waste • Kept closed unless adding more waste • Inspect weekly with documentation • Manage properly • Tanks* • Secondary Containment* • Release detection equipment • Inspected daily with documentation * Certified by a Professional Engineer

  32. Hazardous Material Storage Area • Must have a sign identifying the area as the“Hazardous Material Storage Area” • Required by OSHA and the EPA • Must be kept dry • Indoors or under roof • Must be inspected weekly • Use IG HW 2 - Container Inspection or IG OSHA 3 - Plant Inspection • Tracked on IG HW 3 - Container Log

  33. Hazardous Material Storage Area • The storage area may include: • Hazardous Material received that are part of the galvanizing process, like Preflux bags, Caustic beads, Chromic Acid or Aqueous Ammonia. • Hazardous Waste being stored before being shipped. • There must be clear delineation between the Hazardous Materials and the Hazardous Waste stored in this area. • Do not store in this area Skims, Dross or Zinc Residues waiting to be shipped

  34. US DOT Shipping Papers for Hazardous Wastes Two Documents are required: • Hazardous Waste Manifest • Each plant is responsible to make sure the manifest is filled out correctly and that the information is accurate • Land Disposal Restriction (LDR) • May be filed once if the waste doesn’t change with annual renewal, or • May be included with each shipment

  35. US DOT Shipping Papers for Hazardous Wastes • Hazardous Waste Manifest • Each plant is responsible to make sure the manifest is filled out correctly and that the information is accurate • Dual authority • US EPA • US DOT • Emergency Number: 24/7/365 • Must be answered by a real person • Infotrac: 1-800-535-5053

  36. US DOT Information Required on a Hazardous Waste Manifest • Proper Shipping Name (according to the US DOT) • UN Number (“UN” plus 4 digits) • Packing Group (degree of hazard) • I – Most hazardous • II – Moderately hazardous • III – Mildly hazardous • DOT Hazard Class

  37. US DOT Information Required on a Hazardous Waste Manifest • Example for waste strip acid: • Reportable Quantity?, Waste, UN #, Proper Shipping Name, Hazard Class and Packing Group • RQ, UN 3264, Waste Corrosive Liquid, Acidic, Inorganic, N.O.S., 8, II

  38. US DOT Information Required on a Hazardous Waste Manifest • Are you shipping more than the Reportable Quantity or RQ? • EPA has established reporting thresholds for hazardous wastes • The RQ is determined by the “Proper Shipping Name” of the waste and the amount being shipped • If you are shipping a quantity that is more than its reporting threshold the letters “RQ” must be added to the hazardous waste manifest.

  39. US DOT Information Required on a Hazardous Waste Manifest • DOT Hazard Class • 1 – Explosives (6 types) • 2 – Gas (3 types) • 3 – Flammable and Combustible Liquids • 4 – Flammable Solids (3 types) • 5 – Oxidizers and Organic Peroxide • 6 – Poisonous and Infectious Substances • 7 – Radioactive • 8 – Corrosives • 9 – Miscellaneous hazardous material • None –Other Regulated Material (ORM-D)

  40. US EPA Information Required on a Hazardous Waste Manifest • EPA Hazardous Characteristic Codes • D001 – Ignitability • D002 – Corrosive • D003 – Reactivity • D004 – Toxicity • D005 – Barium • D006 – Cadmium • D007 – Chromium • D008 – Lead • D009 – Mercury • D010 – D043 (Other chemicals and metals) • Other information • Identify (Primary Hazard)

  41. HAZARDOUS WASTE MANIFEST

  42. HAZARDOUS WASTE MANIFEST

  43. Hazardous Waste Manifest Closed-Loop Confirmation • One copy stays with the Generator • One copy stays with Transporter 1 • One copy stays with the TSDF • One copy returns to the Generator • If the manifest has not returned in 35 days you are required to call TSDF and notify Sam. • If you haven’t received it in 45 days you are required to notify EPA and Sam.

  44. Land Disposal Restrictions • Land Disposal Restriction or LDR • Tells the TSDF how the waste is to be handled and disposed of • Options for Sending an LDR to TSDF: • Mail or fax before each shipment • Staple to manifest with each shipment • If you are sending the same waste over and over again… you may send the LDR to TSDF one time, but you must renew it every year via letter or resending the LDR with cover letter

  45. Hazardous Waste Manifest Shipping Discrepancies • When the “Original – Return to Generator” copy of the manifest is returned to you… • Check for Discrepancies: • Quantity – Count or amount is wrong • Type – Wrong waste sent • Residues • Partial Rejection • Full Rejection (If you receive notice of a discrepancy by fax, phone call or on a returned manifest you must notify the NCM immediately!) • Staple the “Return to Generator” copy to the original “Generator” copy and file.

  46. US DOT Hazardous Waste Shipping Labels • Accountability Label • TSDF Address • Shipper’s Address • Hazardous Waste Manifest Number • Container ID: _____ of _____ • Weight of each Container • Hazard Label • Proper Shipping Name • UN Number • EPA-required notification • US DOT Hazard Class “Diamond”

  47. Hazardous Waste Shipping Labels: 1. Accountability Label

  48. Hazardous Waste Shipping Labels: 2. Hazard Label

  49. Hazardous Waste Shipping Labels: 3. DOT Hazard Class Label

  50. 3 1 2 Hazardous Waste Shipping Labels:

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