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RCRA Boot Camp ( Basic Training for the Newly Inducted)

RCRA Boot Camp ( Basic Training for the Newly Inducted). 2013 College & University Hazardous Waste Conference Charlottesville, Virginia August 4-7, 2013. Objectives:. Summarize, Demonstrate and Provide Experience Completing the Waste Determination Process

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RCRA Boot Camp ( Basic Training for the Newly Inducted)

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  1. RCRA Boot Camp(Basic Training for the Newly Inducted) 2013 College & University Hazardous Waste ConferenceCharlottesville, VirginiaAugust 4-7, 2013

  2. Objectives: • Summarize, Demonstrate and Provide Experience Completing the Waste Determination Process • Discuss Special Wastes (Universal Waste, Oil, Etc.) • Summarize Generator Issues (Status, ID#, Subpart K) • Summarize Land Ban & Transportation Issues • Discuss Compliance Strategies & Inspections

  3. Schedule: • 10:00 – 10:10 Introductions & Welcome • 10:10 – 11:00 Waste Determinations • 11:00 – 11:10 Break • 11:10 – 12:00 Waste Determinations (continued) • 12:00 – 13:00 Lunch • 13:00 – 13:30 Special Wastes (UW, Oil, etc.) • 13:30 – 14:00 Generator Issues (Status, ID#, Storage) • 14:00 – 14:10 Break • 14:10 – 14:30 Land Ban & Transportation Issues • 14:30 – 15:00 Compliance Strategies & Inspections

  4. Bill Diesslin, ARM, CHMM, CSP Associate Director, EH&S Iowa State University Sean B. Whalen, ASP, CHMM Environmental Manager, EH&S Iowa State University Introductions

  5. The Need For RCRA • $750 billion chemical industry • 70,000 different chemicals • 1,500 new chemicals each year • 50,000 hazardous waste sites • Many avenues of exposure • Many chemical risks are poorly understood

  6. Times Beach, Missouri

  7. Love Canal

  8. Valley of the Drums

  9. Resource Conservation & Recovery Act (RCRA) • Enacted in 1976 as an amendment to the Solid Waste Disposal Act (SWDA) • Main objectives: • Protect human health & the environment • conserve valuable material • conserve energy resources • Established "Cradle-to-grave" management and tracking of hazardous waste

  10. RCRA Administration • EPA administers RCRA • States may be authorized by the EPA • Rules need to be adopted for state enforcement • Alaska & Iowa do not administer state programs

  11. USEPA Regions

  12. Waste Determinations • What • Wastes to consider • When • Not defined by regulation • Who • Interpretive letter • How • Objective of this class

  13. Waste Determinations (what) • Solid Waste • To be hazardous waste a material must first be solid waste • Discarded material • Not excluded by 40 CFR 261.4(a) • Discarded material • Abandoned material • Recycled material • Inherently waste-like material • A military munition as defined by 40 CFR 266.202

  14. Waste Determinations (what) • Materials are solid waste if they are abandoned • Disposed • Burned or incinerated • Accumulated, stored or treated in lieu of disposal or incineration • Materials are solid waste if they are recycled • Use constituting disposal • Burning for energy recovery • Reclaimed • Accumulated speculatively

  15. Waste Determination (what) • Use constituting disposal • Materials applied to or placed on land in a manner that constitutes disposal • Material used to produce products that are land applied • Commercial chemical products (261.33) are not solid waste if land application is ordinary manner of use. • Burning for energy recovery • Materials burned or used to produce fuel • Commercial chemical products (261.33) are not solid waste if they are themselves fuels.

  16. Waste Determination (what) • Inherently waste-like materials • Materials that are solid waste when recycled in any manner • F020 – F023, F026, F028 • Some materials are not solid waste when recycled • Used as an ingredient in an industrial process • Used as an effective substitute for a commercial chemical product • Returned to its original process

  17. Waste Determination (when) • Not overtly stated in regulation • Often implied that it must be done at the moment the waste is generated • Topic discussion of discussion in OSW

  18. Waste Determination (who) • C&U interpretation • 08/16/2002 • RCRA On-line #14618 • Definition of “person” • individual, firm, agency, corporation, partnership, association, state, municipality, commission • Waste determination can be made by: • Lab personnel • EH&S staff • Other qualified person

  19. Waste Determination (how) • Outlined in 40 CFR 262.11 • Determine if material is solid waste • As discussed • Determine if waste is excluded [261.4] • Determine if the waste is a listed hazardous waste • Determine if the waste is a characteristic hazardous waste

  20. Waste Exclusions • Outlined in 40 CFR 261.4 • Materials which are not solid wastes • 40 CFR 261.4(a) • Solid wastes which are not hazardous • 40 CFR 261.4(b) • Hazardous wastes which are specifically exempt • 40 CFR 261.4 (c) - (g)

  21. 40 CFR 261.4(a) • Domestic sewage. Domestic sewage means untreated sanitary wastes that pass through a sewer system. • A mixture of domestic sewage and other wastes that pass through a sewer system to a publicly-owned treatment works (POTW). • A wastewater discharge subject to permitting by the National Pollutant Discharge Elimination System (NPDES).

  22. 40 CFR 261.4(a) • Special nuclear or by-product material as defined by the Atomic Energy Act of 1954, as amended by 42 USC 2011. • Excluded scrap metal being recycled. • Shredded circuit boards being recycled. • Materials that meet the requirements for comparable fuels or comparable syngas fuels as defined in 40 CFR 261.38

  23. 40 CFR 261.4(b) • Household waste • Solid waste generated by agricultural activities that are returned to the land as fertilizer. Included both plant and animal production. • Mining overburden returned to the mine. • Fossil fuel combustion residues (fly ash, bottom ash, etc.) • Trivalent chromium waste.

  24. 40 CFR 261.4(b) • Solid waste from ores and minerals. • Treated lumber used for its intended purpose. • Petroleum contaminated media subject to corrective action. • Reclaimed CFCs. • Properly managed non-terne plated used oil filters.

  25. 40 CFR 261.4(c) – (g) • Hazardous waste samples • Treatability study wastes • Others • Rare in acadamia

  26. Listed Wastes • Waste from non-specific sources • “F-List” • Waste from specific sources • “K-List” • Commercial chemical products • “P-List” • “U-List”

  27. F-Listed Wastes • Hazardous waste from non-specific sources • Spent materials • F001 – F005 are common wastes in academia • F027 waste is occasionally found at academic institutions and is subject to acute waste limits

  28. K-Listed Wastes • Spent material from specific industrial processes • Very rare in academia

  29. Acute Hazardous Wastes • P-Listed wastes • Unused commercial chemical products • Sole active ingredient • Waste containers require triple rinsing

  30. Toxic Hazardous Wastes • U-Listed wastes • Unused commercial chemical products • Sole active ingredient

  31. Characteristic Hazardous Wastes • Ignitable (D001) • Corrosive (D002) • Reactive (D003) • Toxic (D004 – D043)

  32. Ignitable Wastes • A liquid with a flash point less than 140º F • Does not include aqueous solutions containing less than 24 percent alcohol by volume • A material other than a liquid capable of causing fire under standard temperature and pressure that burns so vigorously and persistently that it creates a hazard • An ignitable compressed gas

  33. Ignitable Wastes (Oxidizers) • For many years, 40 CFR 261.21 (a)(4) incorrectly referred readers to 49 CFR 173.151 for the definition of an oxidizer • Mistake was due to revision of 49 CFR in 1990 • EPA determined that excluding DOT definition from RCRA was impractical • Resulted in the 2006 definition that is actually more confusing • Includes numerous notes

  34. Revised Oxidizers (2006) • Substance that yields oxygen readily to stimulate combustion of organic matter • “such as” chlorate, permanganate, nitrate, inorganic peroxide • Organic peroxides except: • Class A & B Explosives • Forbidden for transport • Predominant hazard is other than organic peroxide • Does not present a hazard for transportation

  35. Corrosive Wastes • An aqueous solution with a pH less than or equal to 2.0 or greater than or equal to 12.5 • A liquid that corrodes steel at a rate of 0.25 inches per year • Solids, by definition, can’t be corrosive

  36. Reactive Wastes • Normally unstable and readily undergoes violent change without detonating • Reacts violently with water • Forms potentially explosive mixtures with water • Generates toxic gas when mixed with water • Cyanide and sulfide bearing wastes

  37. Reactive Wastes • Capable of detonation or explosion when ignited or heated under confinement • Can detonate or explode at standard temperature and pressure • Forbidden explosives as defined in 49 CFR 173.53

  38. Toxic Wastes • Wastes that contain hazardous contaminants that may “leach” into groundwater if landfilled • A sample of the waste is subjected to Toxicity Characteristic Leaching Procedure (TCLP) • TCLP “leachate” is then subjected to chemical analysis • Analytical results that exceed limits listed in 261.24 are hazardous waste

  39. Toxic Wastes • TCLP is not always necessary • May use generator knowledge to assign waste codes • May use “total” analysis with a 20x dilution factor in lieu of TCLP process

  40. Toxic Wastes & SDWA

  41. Toxic Wastes & SDWA

  42. Mixture Rule • Characteristic waste + solid waste = characteristic waste if the mixture still exhibits the waste characteristic • Wastes listed for a characteristic + solid waste = listed waste if the mixture still exhibits the waste characteristic • All other listed wastes + solid waste = listed waste • Mixing is treatment

  43. Derived-From Rule • Treatment residue from characteristic wastes are hazardous if the exhibit a waste characteristic • Treatment residue from wastes listed solely for a characteristic are hazardous waste if they exhibit a waste characteristic • Treatment residue from all other listed wastes remain listed

  44. Questions

  45. Example #1 Unused reagents in their original containers are left over from a research project in the Biology department. These are common reagents that would be readily used if transferred to the Chemistry department. Are the reagents solid waste?

  46. Example #2 A researcher has retired and left behind a supply closet filled with dust covered reagents. Dates on many containers indicate that they are more than 30 years old. Are the reagents solid waste?

  47. Example #3 During a lab inspection you encounter four unlabeled glass containers filled with colorful liquids. All lab staff are aware of the containers but have no idea what they contain. Are these materials solid waste? If so, are they hazardous waste?

  48. Example #4 The campus motor pool uses a power washer to clean automobile engines. A degreaser is applied to the engine as a pretreatment prior to cleaning the surface. Rinse water enters a floor drain that is connected to the sanitary sewer. Is the rinse water hazardous waste?

  49. Example #5 A radio isotope lab is being decommissioned. Twenty lead bricks that were used for shielding are discovered. The bricks are of no use to any other laboratory on campus. Are the bricks solid waste? Are they hazardous waste?

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