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ADEQHazardous WasteTop 10 Violations

Kalie Rumaner ADEQ Hazardous Waste Unit

January 2, 2019

Civil Rights Program Policy

“ADEQ will take reasonable measures to provide access to department services to individuals with limited ability to speak, write, or understand English and/or to those with disabilities. Requests for language interpretation services or for disability accommodations must be made at least 48 hours in advance by contacting: Environmental Justice/Title VI Nondiscrimination Program Coordinator at 602-771-4322 or idb@azdeq.gov”

“ADEQ tomará medidas razonables para proveer acceso a los serviciosdel departamento para personas con capacidad limitada para hablar, escribir o entender Inglés y / o para las personas con discapacidad. Las solicitudes de servicios de interpretación del lenguaje o de alojamientode discapacidad deben hacerse por lo menos 48 horas de antelaciónponiéndose en contacto con: Environmental Justice/Title VI Nondiscrimination Program Coordinator at 602-771-4322 or idb@azdeq.gov”

Top 10 Violations

Top 10 Violations

1. Improper labeling, dating, and closing of hazardous waste containers

2. Failure to perform a hazardous waste determination3. Improper treatment, storage, or disposal of hazardous waste4. Failure to label universal waste5. Failure to store universal waste lamps in a closed container6. Failure to demonstrate the length of time that universal

waste has been accumulated7. Failure to inform employees of proper universal waste

handling and emergency procedures8. Failure to comply with the personnel training requirements

in 40 CFR 265.169. Failure to comply with Preparedness & Prevention

requirements in 40 CFR 265, Subpart C10. Failure to comply with contingency plan and emergency

procedures requirements in 40 CFR 265, Subpart D

Containers must be closed, except when actively adding or removing waste

Violation #1: Open Containers of Hazardous Waste

Violation #1: Improper or no Labeling and Dating

Tips for Compliance: Use DOT stickers

Proper waste containment, labeling and dating

Actively adding waste

Make sure the lid is securely latched on the container

Proper Labeling and Dating in Accumulation Area

Your label should include (at a minimum):

1. The words HAZARDOUS WASTE

2. Waste Identification (What is the waste? Include waste codes.)

3. Accumulation start date

Failure to perform a Waste Determination All waste generated on site needs

to be evaluated– (VSQG, SQG, LQG requirement)

Violation #2: Waste Determination

Violation #2: Failure to make a Waste Determination

Tips for Compliance: Waste Determination

Keep supporting documentation on file (e.g. SDS, laboratory analysis, etc.) (required)

Update accordingly with any process changes Wastes are generally thought to be generated as

an output from a process, but wastes can be generated at any point (byproduct, spills, leaks)

Improper treatment of hazardous wasteViolation Example: Improper treatment of hazardous waste or unpermitted treatment

Violation #3: Improper treatment, storage, or disposal of hazardous waste

Violation #3: Improper storage/ uncontained waste

Violation Example: Improper Storage

Violations:1. Dozens of drums containing a

variety of wastes stored on bare ground

2. Leaking waste / soil contamination

3. Inadequate aisle spacing4. No labeling5. Open containers

Improper Disposal of Hazardous Waste

Violation Examples: Improper Disposal

Violation #4/5: Failure to label universal waste and store in a closed container

Violation #6: Failure to demonstrate accumulation start date

Mark each container with the earliest date the waste is generated and accumulate for no longer than one year.

Tips for Compliance: Universal Waste

Label boxes as “Waste”, “Used”, or “Universal Waste”, date and tape shut

Broken Lamps Once a lamp breaks, it releases mercury vapors

into the air so it is important to ensure the immediate cleanup and containment of the lamp debris.

Make sure your facility has proper procedures for reporting and managing broken lamps.

“Accidentally” broken lamps and their debris can be managed as universal waste, whereas, “intentionally” broken lamps and their debris must be managed as hazardous waste

Tips for Compliance: Universal Waste

Violation #7: Failure to train employees on proper universal waste handling and emergency procedures

Incomplete Training Plan

Missing Training Records

Inadequate training documentation

Violation #8: Failure to Provide Training per 40 CFR 265.16

(Only required for LQGs & TSDFs)

Required Emergency Equipment 40 CFR 265 Subpart C: Maintained to minimize possibility of fire,

explosion, or release Equipped with:

Internal communications or alarm system

Telephone or walky-talkies capable of summoning emergency assistance from local emergency authorities

Portable fire extinguishers, spill control equipment, anddecontamination equipment

Water at adequate volume and pressure to supply water or sprinklers or water spray systems

Adequate aisle spacing “No Smoking” sign

Violation #9: Facility Preparedness & Prevention

Violation Examples: Facility Preparedness & Prevention

Not having all required equipment

Accessibility/aisle spacing

Not testing and maintaining equipment

Examples of Compliance: Facility Preparedness & Prevention

Generators need to comply with the requirements of40 CFR 265, Subpart D

This applies to: Large Quantity Generators (LQGs) > 2,200 lbs/month Treatment Storage and Disposal Facilities (TSDFs)

Violation #10: Contingency Plan and Emergency Procedures

Liability Protection

Violation #10: Contingency Plan and Emergency Procedures

Update when processes change Update when Emergency Coordinator is replaced, even

if they are just a temporary placement REMEMBER: Notify ADEQ of updates! NEW: LQGs must submit quick reference guide of

contingency plan to local emergency responders NEW: LQGs must notify EPA 30 days prior to closing a

facility and 90 days after closing the facility

Call us at 602-771-4673or

Update info on myDEQ

Contact the Hazardous Waste Inspections and Compliance

Team for regulatory interpretations or Technical Assistance

(TA) Meetings

Review the lists of major and minor violations found in the

Compliance & Enforcement Handbook

Consult ADEQ or EPA website

Look to your specific industry for tips on how to comply with

the regulations

NEED HELP?

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