Hazardous Waste Management 1 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software...

Hazardous Waste Management 1 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC.

WELCOME

HAZARDOUS WASTE MANAGEMENT

CUSTOMIZED ENVIRONMENTAL TRAINING


INSTRUCTOR

Insert Instructor Name Here


Define Hazardous Waste.

Discuss the Different Types of Generators.

Discuss the EPA Identification Number.

Discuss Container Management.

Discuss Hazardous Waste Accumulation Area Requirements.

Discuss Transportation Requirements.

Examine the Contents of a Contingency Plan.

Discuss the role of the Emergency Coordinator.

Discuss Training Requirements.

Discuss Inspection Procedures.

Discuss Use of Contractors.

OBJECTIVES


Understand the Definition of a Hazardous Waste.

Understand the Different Types of Hazardous Waste Generators.

Understand How to Manage a Hazardous Waste Container.

Be Familiar With the Requirements of a Hazardous Waste

Accumulation Area.

Understand the Transportation Requirements and Reports.

Understand the Contents of a Contingency Plan.

Understand the Role of a Emergency Coordinator.

Understand the Inspection Criteria of a Hazardous Waste

Accumulation Area.

GOALS


BACKGROUND

More than 250 million tons of hazardous waste is generated in the United States annually. That is roughly the equivalent of 1 ton per person.

More than 70,000 types of chemicals are used regularly throughout the world.

There are more than 37,000 illegal hazardous waste dumps in the United States that threaten groundwater and citizen’s health.

This training helps improve environmental compliance with the Resource Conservation Recovery Act (RCRA).


Supervisors

Facility Engineers

Maintenance Personnel

Department Managers

Building Occupants

Process Specialists

Hazardous Waste Handlers

Environmental and Safety Committees

LEARNERS


The goal of this course is to provide supervisors with the tools needed to properly manage a hazardous waste program. It recommends practical, actions that can be carried out by facility management, maintenance personnel and building occupants. The course will help you to integrate good hazardous waste management practices into your existing organization and identify which of your staff have the necessary skills to carry out those activities.

OVERVIEW


WHAT THIS COURSE DOES NOT DO

The course is not intended to provide 40 Hour, 24 Hour training or 8 Hour Refresher Training as directed by 29 CFR 1910.120. However, it can be used as part of the equivalent training as recommended in 29 CFR 1910.120. Both 40-Hour and 24-Hour Training and the 8-Hour Refresher Training require specialized training beyond the intended scope of this course. Where this expertise is needed, outside assistance should be solicited.


RESOURCE CONSERVATION AND RECOVERY ACT (RCRA)

RCRA addresses both hazardous waste and solid waste.

Subtitle C of RCRA, 42 U.S. Code (USC) sections 6921-6939b, establishes standards and procedures for the handling, storage, treatment, and disposal of hazardous waste.

EPA regulations 40 CFR Parts 260-299 establish a “Cradle-to-Grave” system.


FEDERAL REGULATIONS

Pertinent Regulations:

40 CFR 261 – Identification and listing of hazardous wastes.

40 CFT 262 – Standards applicable to generators of hazardous waste

29 CFR 19010.120 – Hazardous waste operations and emergency response.


STATE REGULATIONS

EPA encourages states to develop their own regulatory Hazardous Waste (HW) programs.

States’ regulatory programs must be at least as stringent as the federal EPA regulatory requirements.

Not all states have developed a program.States’ programs may differ from EPA program. Facilities are required to comply with either the federal

EPA requirements or the state’s requirements, whichever is the most stringent.

This training course utilizes federal EPA regulations.


WHAT IS A HAZARDOUS WASTE?

Proper identification of hazardous wastes is a complex task that is fundamental to determining which materials at a facility are subject to the Resource Conservation and Recovery Act (RCRA) requirements.

Four Questions:1. Do the regulations consider the waste to be a solid waste?

2. Is there an exclusion for the waste?

3. Is the waste listed or have the characteristics of a hazardous waste?

4. Has the waste been delisted?


A SIMPLIFIED DEFINITION

RCRA defines a hazardous waste as one that

“causes or significantly contributes to an increase in mortality or an increase in serious irreversible, or incapacitating reversible illness; or poses a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, disposed of, or otherwise managed.”


CHARACTERISTICS OF A HAZARDOUS WASTE

Any solid waste that exhibits one or more of these characteristics is classified as hazardous under RCRA:

Ignitability Corrosivity Reactivity or Toxicity


LISTED HAZARDOUS WASTES

EPA has three categories of listed wastes: Nonspecific source wastes – Examples include:

- Spent halogenated solvents used in degreasing.- Wastewater treatment sludge.

Specific source wastes – Examples include:- Wood preserving residues.- Petroleum refining wastes.

Commercial chemical products – Examples include:- Chloroform - Creosote


ACUTE HAZARDOUS WASTES

Acutely hazardous wastes are wastes that EPA has determined to be so dangerous that small amounts are regulated in a manner similar to larger amounts of hazardous wastes.

Examples of acutely hazardous wastes include:

– Arsenic Oxide

– Benzene

– Carbon Disulfide

– Mercury

– Sulfuric Acid


Conditionally Exempt Small Quantity Generator (CESQG)

CESQGs:

Generates no more than 100 kg (220.46 lb.) of hazardous waste or 1 kg (2.20 lb.) of acutely hazardous waste in a calendar month.

Accumulates no more than 1,000 kg (2,204.62 lb) of hazardous material at any one time.


SMALL QUANTITY GENERATOR (SQG)

SQGs:

Generates between 100 kg (220.46 lb.) and 1,000 kg (2,204.62 lb) of hazardous waste in a calendar month.

Can not accumulate more than 180 days on site unless waste is to be transported more than 200 miles, then it can accumulate 270 days.

Accumulates no more than 6,000 kg (13,227.73 lb) of hazardous material or 1 kg (2.20 lb) of acutely hazardous material at any one time.


LARGE QUANTITY GENERATORS (LQG)

LQGs:

Generates greater than 1000 kg (2204.62 lb.) of hazardous waste or 1 kg (2.20 lb.) of acutely hazardous waste in a calendar month.

Accumulates no more than 90 days on site.


TIME LIMITS FOR HW ACCUMUMULATION AND STORAGE

Accumulation: the initial amount of hazardous waste that is collected before the storage time limit applies.

Storage: the holding of containerized or isolated hazardous wastes either at the point of generation or at a specially designed storage area.

Time Limit Definitions:


TIME LIMITS FOR HW ACCUMUMULATION AND STORAGE

LQGs:

90 Day Rule for Accumulation

SQGs:

180 Days 270 Days if shipped >200 miles.

CESQGs:

None


EPA ID NUMBER

A generator must not treat, store, dispose of, transport, or offer for transportation, hazardous waste without having received an EPA identification number.

EPA and states use these 12-character numbers to monitor and track hazardous waste activities.

Call the Regional EPA to obtain an EPA Identification Number.


SECURITY

Must minimize the possibility of fire. Assigned personnel shall be responsible. Storage areas shall be marked:

“DANGER HAZARDOUS WASTE AREA – UNAUTHORIZED PERSONNEL KEEP OUT”


SECURITY

A 24-hour surveillance system.

OR An artificial or natural barrier which

completely surrounds the active portion of the facility (e.g., fence).

A sign reading: "Danger - Unauthorized Personnel Keep Out"


INCOMPATIBLE WASTES

1. May cause corrosion or decay of containment materials (e.g., container liners or tank walls) or

2. Commingling with another waste or material under uncontrolled conditions may cause a fire, explosion or another type of undesirable reaction.

Wastes are incompatible for:


IGNITABLE OR REACTIVE WASTES

Use safe management practices to handle incompatible wastes.

Separate incompatible wastes using a dike, wall, berm, or other device.

Keep ignitable or reactive wastes at least 50 feet from property line.


CONTAINER MANAGEMENT

Have no more than 1 inch of residue remaining. For containers over 110 gallons have no more than .3% of the total container weight remaining. For compressed gasses, container’s pressure should approach atmospheric pressure. For containers holding acute hazardous wastes, triple rinsed or equivalent cleaning.

Empty Containers Previously Holding Hazardous Wastes Must:


CONTAINER MANAGEMENT

Keep containers closed. Containers should be in good condition. Containers and waste should be compatible. Verify that handling and storage practices do not damage containers.


SATELLITE ACCUMULATION POINTS

No more than 55 gal. Under the direct control of a single

operator Waste is transferred to a storage

area within three days. Only for SQG and LQG.


SATELLITE ACCUMULATION AREAS

Containers must be in good condition.

Containers must not be compatible with wastes.

Containers are to be kept closed. The containers are marked

HAZARDOUS WASTE. The containers are marked with the

date accumulation began.


PRINCIPLES OF MATERIALS HANDLING

The least handling is the best handling.

Standardize handling procedures. Plan ahead. Never exceed safety capacities. Learn the proper use of Material

Handling Equipment.


CONTAINER LABELING

Labeling Requirements: The accumulation start date and/or the date the 90-day storage period began; The words “Hazardous Waste”; The composition and physical state of the wastes; Warning words indicating the particular hazards of the waste The name and address of the facility

Before transportation off-site, a generator must label each package in accordance with Department of Transportation regulations.


AISLE SPACE

Containers are not stored more than 2 high and have pallets between them

Containers of highly flammable wastes are electrically grounded

At least 3 ft. of aisle space is provided between rows of containers.


COMMUNICATIONS

Each area must have both: Internal – Voice or alarms to

warn facility personnel.External – Telephone, hand-held

two way radio capable of contacting emergency responders.


EMERGENCY EQUIPMENT

Portable fire extinguishers and fire control equipment.

Spill control equipment Decontamination equipment Fire hydrants or other source of

water Showers or eyewash facilities. Emergency equipment should be

checked periodically to insure they are working properly.

Other Emergency Equipment in Storage Areas:


TRANSPORTERS AND FACILITIES RECEIVING WASTES

Responsibility of wastes is “cradle-to-grave.”

Facility could still be liable for the hazardous waste after it leaves your facility.

Ensure transporters and TSDFs have an EPA Identification number and the required permits.

Transporters and TSDFs should have a good regulatory record.


MANIFESTS

Generators of Hazardous Waste are Required to use Manifests.

Signed Copies of Returned Manifests Must be Kept for Three Years.

Manifests Not Required for Recycling of Hazardous Wastes.

Retention of Records is Extended Automatically During Unresolved Enforcement Actions.


EXCEPTION REPORT

Exception reports must be submitted to the regulatory

agency when a signed manifest copy was not received within 60 days of the waste being accepted by the initial transporter.

Exception reports must be filed when certain delays or difficulties occur when exporting hazardous waste out of the United States.

Exception reports must be kept for at least three years.


BIENNIAL REPORT

Generators who shipped hazardous waste off-site must submit a biennial report by 1 March of even numbered years.

The Biennial Report Form (EPA Form 8700-13A) is to be submitted in at timely manner.

Copies of Biennial Report are to be kept for at least three years.


CONTINENCY PLAN

Generators must have a contingency plan. The contingency plan should be designed to

minimize hazards to human health or the environment The plan needs to include the following:

- A description of actions to be taken during an emergency- A description of arrangements. - Names, addresses, and phone numbers of emergency coordinators - A list of all emergency equipment- An evacuation plan


CONTINENCY PLAN

Copies of the contingency plan and all revisions are maintained at the facility and organizations which may be called upon to provide emergency services.

The contingency plan needs to be routinely reviewed and updated, especially when:

- The applicable regulations are revised

- The plan fails in an emergency

- The facility changes

- The list of emergency coordinators changes

- The list of emergency equipment changes.


AFTER AN INCIDENT

Generator operators must record the time, date, and details of any incident that requires implementing the contingency plan.

A written report has to be submitted to the governing regulatory agency within 15 days after the incident.


EMERGENCY COORDINATOR

Each generator must have an emergency coordinator on the facility premises or on call at all times.

The emergency coordinator is to be thoroughly familiar with the facility operations and the contingency plan.

The following information needs to be posted next to telephones and at the hazardous waste accumulation site: - Name and telephone number of emergency coordinator- Location of fire extinguishers and spill control materials- Location of fire alarms (if present)- Telephone number of fire department.



Emergency Coordinators During an Emergency Must:

Immediately activate facility alarms or communication systems Identify the character, exact source, amount, and a real extent of any released materials Assess possible hazards to human health or the environment Take all reasonable measures necessary to ensure that fires, explosions and releases do not occur, recur, or spread to other hazardous waste at the facility.



These measures must include where applicable: Stop processes and operations at the facility Monitor for leaks, pressure buildup, gas generation Provide for treatment, storage, or disposal of

recovered waste, contaminated soil, or surface water, or other material immediately after emergency

Ensure that no waste that may be incompatible with the released material is treated, stored, or disposed of until cleanup is completed

Ensure that all emergency equipment is cleaned Notify regulators


TRAINING

All personnel who handle hazardous waste must meet certain training requirements.

The training program should be directed by a person trained in hazardous waste management procedures.

Potential topics include: - Waste turn in procedures- Identification of hazardous wastes- Container use, marking, labeling and on-site transportation- Manifesting and off-site transportation- 90 day storage area management- Personal health and safety and fire safety


TRAINING

Training program needs to include contingency plan implementation.

This should include where applicable:- Automatic waste feed cut-off systems- Emergency and monitoring equipment- Operation of communications and alarm systems- Response to fire or explosion- Response to groundwater contamination incidents- Response to leaks or spills- Shutdown of operations.


TRAINING

The new employee training must be completed within six months.

Need an annual review of initial training. No unsupervised employees until

training is complete. Waste storage area managers and

hazardous waste handlers have to have required training.


TRAINING RECORDS

Must maintain training records all facility staff who manage hazardous waste.

The training records shall include:

- Job title and description

- Written description of how much training each position will obtain

- Documentation of training received by name.

Training records are to be retained for three years after an employee leaves the facility.


GENERAL INSPECTION REQUIREMENTS

Facilities are required to have a written plan and schedule for inspection and monitoring requirements for containers and meet specific inspection requirements. Logs and checklists should be specific to facility being inspected.



INSPECTION LOG

Facility Inclusive Dates:

From:_________ To: __________

Date Inspector’s Name

Signature Areas InspectedGeneral Containers Tanks

Deficiencies Noted



DEFICIENCY REPORT

Inspector: If a deficiency is noted, please complete the following information, make a copy and report to the Facility Manager. You must verify that corrective actions have been taken.

Date of Report Description of Deficiency

Corrective Action Needed

Correction Verified

(Date/Initials)


GENERAL CHECKLIST

Checklist Items Should Include: Structures Safety Equipment Security Equipment Communication Equipment Facility Equipment


CONTAINER AND TANK CHECKLISTS

Containers Should be Checked For: Integrity Labels Compatibility of Wastes Distance from Fence Line Aisle Space Secondary Containment

Tanks Should Have Their Own Checklist


EPA’s AUDIT POLICY

EPA’s 1995 Audit Policy

EPA will not seek gravity-based penalties and will not recommend criminal prosecutions for companies that meet the requirements of the policy.

Companies are required: to promptly disclose and correct violations, to prevent recurrence of the violation, and to remedy environmental harm.


COMPARISON OF RCRA GENERATOR REQUIREMENTS

Requirement CESQG SQG LQG

Quantity Limits 100 kg/mo

(220.46 lb/mo)

100 kg/mo

(220.46 lb/mo) to 1000 kg/mo

(2204.62 lb/mo)

>1,000 kg/mo (2,204.62 lb/mo)

Acute Waste Limits

1 kg/mo

(2.20 lb/mo)

1 kg/mo

(2.20 lb/mo)

None

Facility Receiving Waste

State approved RCRA, interim status or exempt recycling facility

RCRA permitted, interim status, or exempt recycling facility.

RCRA permitted, interim status, or exempt recycling facility.

EPA ID Number Not Required Not Required Required




Determination whether solid waste is hazardous

Yes Yes Yes

RCRA Personnel Training

Not Required Basic Training Required

Required

Exception Report Not Required Required within 60 days of HW being accepted by initial transporter

Required within 45 days of HW being accepted by initial transporter

Biennial Report Not Required Not Required Required




On-site Accumulation Limits (without permit)

1,000 kg (2,204.62 lb)

6,000 kg (13,227.73 lb)

Any quantity

Accumulation Time Limits (without permit

None 180 days (270 if transported more than 200 miles)

90 days *

Storage Requirements for Accumulated HW

None Basic requirements with technical standards for containers.

Full compliance with container or tank management

Use Manifests No Yes Yes

Contingency Plan

No No Required


Remember, You Control Your Facility or Area!

Review Procedures With Them Before Starting the

Job!

Ensure They Are Properly Trained!

Determine Their Environmental Compliance Record!

Determine Who Is in Charge of Their People!

Determine How They Will Affect Your Facility’s

Environmental Compliance!

TIPS FOR USING CONTRACTORS


ELEMENTS OF SUCCESSFUL HAZARDOUS WASTE MANAGEMENT

1. DETAILED WRITTEN CONTINGENCY PLAN.

2. DETAILED WRITTEN INSTRUCTIONS ON INSPECTIONS

AND THE ACCOMPANYING LOGS AND RECORDS.

3. EXTENSIVE EMPLOYEE TRAINING PROGRAMS

4. PERIODIC REINFORCEMENT OF TRAINING

5. SUFFICIENT DISCIPLINE REGARDING IMPLEMENTATION

6. PERIODIC FOLLOW-UP


THE IMPORTANCE OF A CLEAN ENVIRONMENT

“I would ask all of us to remember that protecting our environment is about protecting where we live and how we live. Let us join together to protect our health, our economy, and our communities -- so all of us and our children and our grandchildren can enjoy a healthy and a prosperous life.”

Carol Browner Former EPA Administrator

Hazardous Waste Management 1 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software...

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