draft modified hazardous waste generator training.ppt · mercury rubber flooring, mercury gas flow...

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License No. 0451271 Innovative Solutions. Enduring Principles.

Hazardous Waste Generator

Training

Hazardous Waste Generator

Training


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Overview• Laws & Regulations

• Hazardous Waste Procedures/Inspections• Weekly Inspections

• PPE

• Empty Container Rule

• Hazardous Waste Characteristics

• Hazardous Waste Paperwork

• Accumulation Rules• Hazardous Waste Storage Areas

• Hazardous Waste Labeling

• Accumulation Times

• Incompatibility of Wastes

• Emergency Response


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Laws & Regulations

• Federal Regulations

– Code of Federal Regulations (CFR)

• EPA regulation Title 40 CFR

• OSHA regulation 29 CFR

• DOT regulation 49 CFR

• HWCL (Hazardous Waste Control Law) Regulation

– California Code of Regulation Title 22(CCR)

– California Health & Safety Code (CH&SC)

DTSC Fact Sheet


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Waste Regulations• Congress defined waste and gave statutory authority to the Environmental Protection Agency (EPA) to regulate it. RCRA(Resource Conservation and Recovery Act) had cradle-to-grave control that regulated the generation, transportation, treatment, storage and disposal of hazardous waste.


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Waste Regulations

• 1984, RCRA amended to include HSWA (hazardous and solid waste amendments), requiring generators to:

– certify that they have a waste minimization program in place (Small waste generators need to make a good faith effort to minimize no written program needed. section title 22 66262.27)

– identify efforts to be taken to reduce the quantity and toxicity of the waste

– Requirement of Land Ban/LDR


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California• RCRA allows California to implement its own RCRA program

• The program must be at least as stringent

• Multi agency and levels of government– Federal EPA (Region 9 – San Francisco)

– California EPA (Cal-EPA - Sacramento)

– Department of Toxic Substance Control (DTSC)

– Local (city or county) Certified Unified Program Agencies (CUPA)

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CUPAs & Other Agencies

• CUPA – Responsible for applying statewide standards in its jurisdiction of the following programs• Hazardous Waste Generator Program

• Hazardous Management Plans & HM Inventory

• Aboveground Petroleum Storage Act (New 2008)

• Underground Storage Tank Program

• HM Release Response Plans & Inventory Program

• Above Ground Storage Tank Program

• Onsite HW Treatment Tiered Permitting Program


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What is the CUPA looking at during

Inspections?• Inspectors can:

– Inspect operations and waste storage areas

– Review Waste Inspection Records

– Training Records

– Review All Paper work associated with Manifests

– Ask employees questions

– Review Consolidated Emergency Response/Contingency Plan


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Most Frequent Violations Cited include

• Marking and Labeling missing or incorrect

• Lack of training or no training

• No documentation of inspection of waste

storage areas or inspections not conducted

properly

• Record keeping of associated paperwork

(example Manifests, LDR and waste profiles)


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Conduct weekly Inspection of waste

storage areas.• Inspection items include

– Containers are not open, damaged or leaking

– Correct Labeling (Satellite or Haz Waste Area)

– Initial accumulation start date on label

– Incompatibles are not stored together

– Secondary containment and containment area is

clean and dry

Unidocs Inspection Form


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Personal Protection

• Choice based on type of exposure the material represents

• Routes of entry

– Inhalation

– Absorption

– Ingestion

– Injection


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Personal Protection• Four levels

– Level A• Highest level of respiratory, dermal and eye protection

– Level B • Highest level of respiratory protection, lower level of dermal protection

– Level C• Lower level of respiratory and dermal protection

– Level D• No respiratory and limited dermal protection

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Disposal of Empty Containers

• Did the container hold acute or extremely hazardous material? If so treat as hazardous

waste.

• Is the container completely empty?

– No liquid can’t drain when tilted in any direction.

– No material remains and no encrusted material.

• How large is container and is it recyclable?

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Managing Empty Containers


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What exactly is a hazardous waste?

EPA (40 CFR § 261.2) defines a hazardous waste as any material that is “discarded, abandoned, or inherently wastelike… which because of its quantity, concentration, or physical, chemical, or infectious characteristics may…pose a hazard to human health or the environment.”

Inherently Waste Photo


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Hazardous Characteristics

When does a material first become a waste?

• When a material can no longer be used for its

original intent.

• When “Inherently” waste like conditions are

obvious. Expired, discarded, no longer used….

• When you deem it to be a waste. It looks good

but you no longer need it.


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Hazardous Characteristics• Determining whether a material is hazardous is the first challenge you face in

the hazmat identification process.

Ignitable Corrosive Reactive ToxicIgnitable Corrosive Reactive ToxicIgnitable Corrosive Reactive ToxicIgnitable Corrosive Reactive Toxic

Defining HW


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California UWR - WastesUniversal Wastes are:

– Hazardous waste batteries

– Hazardous waste thermostats

– Hazardous waste lamps

– Hazardous waste cathode ray tubes (CRT)

– Mercury-containing equipment

– Consumer electronic devices (CEDs)

– Non-empty aerosol cans

UW Label


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California UWR - WastesUniversal waste batteries

– All hazardous waste batteries except vehicle (cranking) spent lead-acid batteries

– Hazardous for:

• Corrosivity – Alkaline or acidic

electrolyte

• Heavy metals – Lead, zinc, nickel, cadmium, mercury, silver, etc

• Reactivity – Lithium (unspent)Lithium Dangers

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California UWR - Wastes

• Mercury-containing equipment: Thermostats, mercury switches, mercury thermometers, pressure or vacuum gauges, dilators and weighted tubing, mercury rubber flooring, mercury gas flow regulators, dental amalgams, counterweights, dampers and mercury added novelties such as jewelry, ornaments and footwear.


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California UWR - WastesUniversal waste lamps

Hazardous due to:

– Mercury content

(fluorescent tubes, high

intensity discharge,

sodium lamps)

– Reactivity (low pressure

sodium)

– Leaded glass (some HID

lamps)


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California UWR - WastesNon-empty aerosol cans

– Empty means that all the contents are used that could be used when the delivery mechanism functions properly

– Hazardous due to reactivity (and…)


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California UWR - Wastes

Waste cathode ray

tubes (CRT)

– Hazardous due to lead content

– Televisions and monitors

–Broken CRT are accepted as UW


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Characteristic WastesHazardous waste definitions are separated into

two (2) different categories:

1. Wastes that Exhibit one of the following.• Ignitability, reactivity, corrosivity, toxicity

2. Wastes that are Listed either RCRA or California.


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Exhibit Wastes

1. Those that exhibit a “characteristic” hazard like:

– Ignitable (D001),- if the waste is a liquid and

has a flashpoint less than 140 degrees F.

– Corrosive (D002)- If the waste has a pH of 2 or less, or 12.5 or more, or if it corrodes steel at

a certain rate.

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Exhibit Wastes Cont.

– Reactive (D003) - if the material reacts with water, forms explosive mixtures with water, generates

toxic fumes or vapors when mixed with water, is a cyanide or sulfide bearing waste which generates hazardous fumes or vapors, or is explosive.

– Toxic (D004-43)- if the wastes contain more than a certain level of some toxic materials. Includes heavy metals, organics, and pesticides.


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Listed Wastes2- The other hazardous waste classification includes those that are specifically “listed” as a hazardous waste.

• Listed Waste includes:

– Over 400 chemicals and chemical wastes are listed wastes. They have codes that begin with P, U, F, or K

• “P” code wastes are acutely hazardous, containers that contain these wastes are also managed as hazardous waste unless triple rinsed.


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Listed Wastes• P and U codes - Discarded commercial

chemical products includes: P codes

(acutely hazardous) and U codes (non-

acutely hazardous).

• They are not considered hazardous

until they are discarded in its unused

form. They can be stored indefinitely

if they are to be used.

• Many P-code wastes are pesticides


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Listed Wastes• F-code wastes are wastes that are listed

from non-specific sources.

– Includes spent halogenated and non-halogenated solvents in

(methylene chloride, CCl4, benzene,

toluene, MEK, etc.)

• K-code wastes includes wastes from

specific industry sources or processes.


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Manifest Resources• Links below are good resources to

understand Hazardous Waste Manifets.

EPA Waste Codes CA Waste CodesCA Restricted Waste Codes

Example Manifest


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Hazardous Waste Disposal Paperwork

• Uniform Hazardous Waste Manifest

• Waste Profiles (Reviewed annually-referenced

on Manifest)

• Bill of lading

• Land Ban/Land Disposal Restrictions

SampleWaste Profile

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Bill of Lading

• Used as the proper shipping papers for Universal Wastes.

• Uniform Hazardous Waste Manifest is NOT

necessary for universal waste shipments.

• Keep records of all shipments and receipts of universal waste for at least 3 years.


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Land Ban/Land Disposal Restrictions

• Land Ban requires wastes sent for disposal have an LDR (Land Disposal Restrictions) form.

• The LDR states the waste has been treated or qualifies to be disposed to land disposal.


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Manifest• The “Uniform Hazardous Waste

Manifest” is the shipping

document that travels with

hazardous waste from the point

of generation, through

transportation, to the final

treatment, storage, or disposal

facility (TSDF).


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Generator Classifications

• Small Quantity Generator – 220 to 2,200 lbs of

hazardous waste and less than 2.2 lbs of acute

hazardous waste per month.

– Acquire an EPA I.D. number.

– Follow EPA storage facility requirements.

– Follow DOT packaging requirements.

– Prepare manifests to accompany shipments.

– Include certification with each shipment on the

proper treatment method.

– Allowed to store waste longer than 90 days.

AccumulationFact Sheet


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Satellite Accumulation AreasSatellite Accumulation Areas

�Waste can be accumulated in satellite areas with minimal

regulatory burden.

�Must be at or near the process generating the waste.

� 55 gallon accumulation limit.

� Excess of 55 gallons must be removed within 72 hours.

� Containers must be Labeled, “Hazardous Waste”, Date accumulation started, Composition and physical state with words that identify the contents and hazardous properties (Ex. Flammability, reactivity, corrosivity, ignitability )


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Hazardous Waste

Accumulation Rules

Label All Containers

– Put Waste labels on all waste bottles i.e.

waste toluene.

– Identify the material. Disposal of unknown

waste is very expensive.

– Complete all information on the label and

date. Including EPA Id#.

HW Label

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Hazardous Waste

Accumulation Rules

1) Store chemical waste in the designated area.

Not on the floor or in the fume hood

2) Keep containers closed.

Never leave funnels in the drums, bottles, or

lids unscrewed.


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Hazardous Waste

Accumulation Rules

– Stoppers or corks are unacceptable.

– Containers must be compatible with the waste.

– Must be properly labeled.

– Must have completed Waste Label

– Do not overfill

• leave 2 inches headspace in all bottles and containers


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Hazardous Waste

Accumulation Rules– Print clearly!

– Do not use formulas, symbols or abbreviations.

– Commingled Waste must equal 100%,

including water and trace chemicals.

– Dilution is not the Solution. Waste placed into

neat (virgin) material makes the whole

container waste!

– Place only compatible materials together.


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Hazardous Waste

Accumulation Rules

Secondary Containment

Secondary containment is required for hazardous waste containers.

• 110% of the individual container.

• If multiple waste containers are stored inside same secondary containment it must be 110% of largest container or 10% of all the containers, whichever is greater.

• If outdoors must be protected from rainfall or sized to handle 24 hours of rainfall.


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Hazardous Waste

Accumulation Rules• Incompatible Wastes must not be stored together.

– Example; Oxidizers and Flammables/Acids and Bases.

• Incompatible wastes should be separated by secondary containment, wall (distance), dike or

other means.


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Emergency Planning

• Contingency Plans– Hazardous Materials Business Plans (HMBP)

• Awareness Level First Responders

• Emergency Response/Contingency Plan

• Hazardous materials inventory

– Business emergency plans (Shut down)

– Evacuation Procedures

HMBPEmergency Response

Guidebook

Title 8 5192Awareness Level

DOT Placards

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Questions?

• Disclaimer – Keenan & Associates is an insurance brokerage and consulting firm. It is not a law firm. We do not give legal advice and neither this training presentation, the

answers providing during the question and answer period, nor the documents accompanying this presentation constitutes or should be construed as legal advice.

You are advised to follow up with your own legal counsel to discuss how this information affects you.

draft modified hazardous waste generator training.ppt · mercury rubber flooring, mercury gas flow...

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