Hazardous waste. The words alone make you think of a material that needs to be handled with extra precaution. Hazardous wastes are process

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1 Hazardous waste. The words alone make you think of a material that needs to be handled with extra precaution. Hazardous wastes are process by-products that usually cannot be recycled due to their chemistry. Their mismanagement can easily create lasting damage to the environment and serious impacts on human health. That s why it is up to each of us who work at facilities that generate hazardous wastes to do our part to properly control and store these wastes before their transfer to a facility that specializes in hazardous waste, treatment or disposal. Container management is an important part of a system for handling hazardous wastes safely, while protecting the environment and the health and well-being of workers and of the public. 1

2 Let s start by listing some goals for your learning. You can track these throughout the session to make sure you are building the base of knowledge you need to work safely with hazardous waste containers. When you have completed this training session, you will be able to: Follow federal guidelines for container storage of hazardous waste at generating facilities; Recognize and employ safe practices for managing hazardous waste containers; Segregate certain hazardous wastes and properly manage those that are incompatible, reactive, or ignitable; Inspect hazardous waste containers and the areas in which they re stored at the facility, and Minimize the use of hazardous materials whenever possible. 2

3 Federal regulations concerning hazardous waste containers are part of the Resource Conservation and Recovery Act (RCRA). This act is usually pronounced as rick-rah or wreck-rah. RCRA is the primary law governing the disposal of solid and hazardous wastes. Congress passed RCRA in 1976 to address the increasing problems the nation faced from its growing volume of waste. RCRA set national goals for: Protecting human health and the environment from the potential hazards of waste disposal; Conserving energy and natural resources; Reducing the amount of waste generated; and Ensuring that wastes are managed in an environmentally sound manner. States have also enacted legislation concerning the regulation of hazardous waste. Management of hazardous waste containers is an essential part of this broad agenda. 3

4 RCRA regulations for containers of hazardous waste are found in 40 CFR Part 264/265, Subpart I for treatment, storage, and disposal facilities, in 40 CFR (b) for small quantity generators of hazardous waste or SQGs, and in 40 CFR (a) for large quantity generators of hazardous waste or LQGs. They include provisions regarding: The design and condition of the containers; How to safely manage containers; What to look for during an inspection; and How to perform closure of a facility with containers. These requirements are designed to ensure that the integrity of the container is not breached; thus, the same standards apply regardless of whether the containers are used for treatment or storage. 4

5 You may have found it surprising that regulations concerning containers are covered in Subpart I of both parts 264 and 265 of 40 CFR as well as in Part 262. The standards in Part 265 are designed to regulate existing facilities until they can comply with the permitted facility standards. These facilities are known as interim facilities. Standards for interim facilities are less stringent than those for permitted facilities. Specifically, in Part 265, Subpart I, regulations do not address requirements for secondary containment or facility closure, whereas the standards in Part 264, Subpart I, which apply to permitted facilities, do. Generators follow the standards in Part 262 in connection with containers. These standards are very similar to those in Part 265, Subpart I for interim status facilities. 5

6 So, why do federal regulations focus on containers? The most important answer is: because containers of hazardous waste present serious environmental and public health hazards. Prior to regulation under RCRA, containers were frequently mismanaged or abandoned. In fact, some of the worst environmental disasters associated with hazardous wastes were caused by the failure of containers. When the abandoned containers became weathered or corroded, the hazardous contents were released, posing a far-reaching danger to human health and the environment. Additionally, many containers were not properly labeled or not labeled at all. As such, they posed hazards due to their unknown contents. 6

7 The past failures of containers, such as 55-gallon drums, and the resulting accidents may make us wonder why containers are used at all for hazardous waste storage, even on a temporary basis. Several other methods can be used to store hazardous wastes at generating facilities, including: Tanks, Drip pads, and Containment buildings. Containers have some advantages over these other methods. 7

8 Compared to tanks, drips pads, or containment buildings, containers such as 55-gallon drums are: Less expensive; Generally, less difficult to manage; Mobile; and Versatile. An owner or operator can use the same container for storage, transportation, and disposal. 8

9 The definition of a container suggests flexibility of use and mobility. Federal guidelines define a container as any portable device in which a material is stored, transported, treated, disposed of, or otherwise handled. This definition in 40 CFR is intentionally broad to encompass all the different types of portable devices that may be used to handle hazardous wastes. For example, a container may be a 55-gallon drum made from steel or plastic, a large tanker truck, a railroad car, a small bucket, or a test tube. 9

10 While different types of containers are commonly used in storing hazardous wastes, the use of all types of containers are governed by federal regulations. Facilities that provide long-term storage or disposal of hazardous wastes are regulated under one set of rules. Facilities that generate hazardous waste and provide short-term storage are also regulated. 10

11 According to federal hazardous waste regulations, storage means holding hazardous waste for a temporary period, at the end of which the hazardous waste is treated, disposed of, or stored elsewhere. Again, this definition in 40 CFR is made intentionally broad to include any situation in which hazardous waste is held for any period of time. 11

12 Hazardous waste generators are subject to regulations concerning: How long hazardous waste may be accumulated on-site; The types of waste management areas allowed; How hazardous wastes are managed until shipment; and How frequently hazardous waste containers are inspected. The exact nature of the regulations governing a facility may vary from state to state and, in some cases, according to federal classifications of generators. Let s review the types of generators, according to this federal classification system. 12

13 A large quantity generator (LQG) may generate 1,000 kilograms (kg), or 2,200 pounds (lb), or more of nonacute hazardous waste, or more than 1 kg, or 2.2 lb, of acute hazardous waste per month, or more than 100 kg, or 220 lb, of residues from a cleanup of acute hazardous waste per month. LQGs have a 90-day limit for on-site accumulation. Accumulation time begins when the first drop of hazardous waste is placed in a container, unless the waste is being accumulated in a satellite accumulation area (SAA). A small quantity generator (SQG) generates less than 1,000 kg, or 2,220 lb, of non-acute hazardous waste per month, or up to 1 kg, or 2.2 lb, of acute hazardous waste per month or up to 100 kg, or 220 lb, of residues from a cleanup of acute hazardous waste per month AND may not accumulate more than 6,000 kg, or 13,200 lb, of hazardous waste at any given time at the facility. SQGs have 180 days to send waste to a treatment, storage, and disposal facility (TSDF). However, if the SQG must transport waste more than 200 miles to the nearest TSDF, the SQG is allowed to accumulate hazardous waste on-site for up to 270 days. A very small quantity generator (VSQG) generates up to 100 kg of nonacute hazardous waste per month, or up to a total of 1 kg of acute hazardous waste per month or up to 100 kg, or 220 lb, of residues from a cleanup of acute hazardous waste per month. There is no time limit for on-site accumulation by VSQGs, but they may not accumulate 1,000 kg or more of nonacute hazardous waste, more than 1 kg of acute hazardous waste, or more than 100 kg of any residue from the cleanup of a spill of acute hazardous waste at any time. As with SQGs, the quantity of VSQG hazardous waste accumulated on-site must never exceed 6,000 kg, or 13,200 lb. It is recommended that regardless of what the regulation stipulates, only the minimum practical amount of hazardous waste should be stored on-site. Keeping an inventory substantially below regulatory allowances is not only prudent but also provides an operational cushion in case there is an unforeseen removal delay. Note: Some state definitions for generators are slightly different. In general, generators that exceed accumulation and storage time limits may be subject to fines and additional reporting requirements. 13

14 Hazardous wastes generated at a facility may be accumulated, that is, stored, temporarily in: A designated central accumulation area that stores LQG containers of hazardous waste for up to 90 days, or A designated central accumulation area that stores SQG containers of hazardous waste for up to 180 days, or Satellite accumulation areas, or SAAs, that are typically in close proximity to where the wastes are generated. The 90-day or 180-day accumulation areas are called central accumulation areas to distinguish them from SAAs. Let s examine the rules for each type of storage area. 14

15 A hazardous waste central accumulation area is a specially designed area for collecting and temporarily holding LQG or SQG hazardous waste before shipment to an off-site treatment or disposal facility. This should be a safe, dry, temperature stable, secure area. Containers must be in good condition, clearly labeled, and kept closed. Incompatible wastes must be segregated or protected from each other, and containers of nonhazardous wastes or raw materials should be segregated from hazardous wastes. In a central accumulation area, an LQG may accumulate an unlimited amount of hazardous waste but may store any given waste container for only 90 days. An SQG may accumulate hazardous wastes for 180 days. At 90 or 180 days, the waste must be sent to a permitted storage, treatment, or disposal facility. 15

16 There are instances where hazardous waste is generated very slowly or is generated in a variety of places throughout the facility. In such situations, wastes may be accumulated in these areas. Such accumulation areas are often referred to as Satellite Accumulation Areas, or SAAs. Numerous rules and standard management practices apply to SAAs. The rules vary from state to state, so be sure to check the applicable regulations for your facility. Hazardous wastes in an SAA must be under the control of the generator and secure at all times. Control can be achieved by having visual contact with the waste. Security may entail locking the waste container or the area the waste container is in. Although there are no time limits associated with SAAs, there are quantity limits. The total volume of the waste in an SAA must not exceed 55 gallons of a nonacute hazardous waste and/or either 1 quart of liquid acute hazardous waste or 1 kg, or 2.2 lb, of solid acute hazardous waste. When this quantity is exceeded, the waste must be labeled with an accumulation start date and be moved to the 90-day or 180-day central accumulation area (as applicable) within three consecutive calendar days as per EPA regulations. Some state regulations vary and, for example, require immediate removal to a 90-day or 180-day central accumulation area. A container must be compatible with its contents. There are certain exceptions to the closed container rule that generally apply to containers. We ll review these last two standards in a few minutes. 16

17 Hazardous waste storage areas should be designed to control hazardous wastes and prevent any incident or accidents from damaging the environment or risking the health of workers or the public. For instance: Storage area floor should have an impervious base. Many state regulations specify 4-inch-thick concrete with no cracks. If the floor is not impervious or there are floor drains nearby, secondary containment for each container must be provided. The volume of the containment must equal 100 percent of the volume of the largest container or 10 percent of the total amount stored in the area, whichever is larger. Note: Even if the floor has an impervious surface and no drains, secondary containment is always prudent. 17

18 Although not always required, all containers holding liquids should have some type of secondary containment, as a backup system to prevent a release into the environment should the container fail. Secondary containment usually consists of a poured concrete pad or other impervious base with curbing to prevent releases of hazardous waste into the environment and to allow drainage of any accumulated liquid to a sump, tank, or other container. Although secondary containment is optional, it is strongly recommended in all situations. For permitted hazardous waste treatment, storage, and disposal facilities, secondary containment is required for containers holding liquid hazardous wastes. However, it is optional for interim facilities and for generators that accumulate hazardous waste on-site without a permit but in accordance with the generator accumulation time requirements in 40 CFR for SQGs and 40 CFR for LQGs. 18

19 Permitted treatment, storage, and disposal facility storage areas holding containers with no free liquids are not required to have secondary containment systems provided that the storage area is sloped or otherwise designed and operated to remove liquids from leaks, spills, or precipitation or the containers are elevated or otherwise protected from contact with accumulated liquid. Free liquids are liquids that readily separate from the solid portion of a waste under ambient temperature and pressure. Containers holding listed dioxin-containing wastes are not eligible for this exemption. 19

20 Safety rules and regulations also apply to containers themselves. It is essential that containers used to store hazardous wastes, even temporarily, are in good condition. Degraded or damaged containers can lead to an environmental or public health incident with lasting, even fatal, consequences. So, make sure all containers are in good condition and not cracked, rusted, or otherwise degraded or damaged. If you have any doubts about a container, do not use it. Hazardous wastes stored in defective containers must be transferred to containers in good condition or handled in another way that will ensure safety. Always handle all containers gently and move them with care using established safe methods to prevent ruptures or leaks. Containers used for hazardous waste, even temporarily, should not be used for any other purpose. 20

21 While hazardous waste is being accumulated on-site by generators, whether in central or satellite accumulation areas, all containers of hazardous waste must be clearly labeled with the words Hazardous Waste and an indication of the hazards of the contents in the container. Containers in the central accumulation area must also be marked with the accumulation start date, which is the date that hazardous waste is first placed in the container. Before transporting the container off-site, containers of 119 gallons or less must be marked with: The name of the generator, Address of the generator, The generator s EPA ID number, The manifest tracking number, and Applicable EPA hazardous waste codes. Container labels must be placed on the side of each container, and the labels must be clearly visible for inspection. Note that some states require additional markings and labels, such as NFPA or DOT labels. To avoid any confusion, place the label or labels on the container BEFORE 21

22 waste is put into it. 21

23 For safe storage, it is essential that containers be made of, or lined with, materials that are compatible with the contents of the containers and will not react with the contents. An incompatible waste may cause corrosion or decay of the container or inner liner or commingle with another waste or material to produce heat or pressure, fire or explosion, violent reaction, toxic dusts, mists, fumes or gases, or flammable fumes or gases. A storage container holding hazardous waste that is incompatible with any other materials stored nearby must be separated from them or protected from them by means of a dike, berm, wall, or other device. Do not place hazardous wastes in unwashed containers that previously held an incompatible waste or material. If you have any doubt about the compatibility of a container and a waste substance, do not store the waste in the container. 22

24 Containers in central accumulation areas must be kept closed at all times, except when adding or removing waste. It is illegal to allow hazardous waste to sit in an open container and evaporate. Inspectors frequently issue violations for failure to keep a container closed. So, don t allow containers to be left open during the workshift, or have containers with open funnels. The only exception to this closed container rule is for containers in SAAs. Although containers of hazardous waste in SAAs must be closed at all times during accumulation, there are exceptions to this rule when: Adding, removing, consolidating waste, or Temporarily venting of a container is necessary, or It s required for proper operation of equipment, or It s necessary to prevent dangerous situations such as buildup of extreme pressure. 23

25 Containers holding ignitable or reactive waste must be at least 50 feet away from the facility s property line. LQGs, but not TSDFs, can apply for an exemption from this restriction from the authority having jurisdiction over the fire code that applies to the LQG s facility. However, not all states will allow this exemption. Keep ignitable or reactive waste away from sources that could cause accidental ignition or reaction. In addition to conspicuously placing No Smoking signs, confine smoking and open flame to specially designated areas when ignitable or reactive waste is being handled. Although these are not regulatory requirements applicable to SQGs, it would be prudent for SQGs to comply with these standards. 24

26 In storage, adequate aisle space between containers of hazardous wastes must be maintained. That means that aisle space must be maintained that allows a waste container to be easily inspected on all sides and allows unobstructed movement of personnel, spill control equipment, and decontamination equipment to any area of the facility in an emergency unless aisle space is not needed for these purposes. State requirements regarding aisle space vary from 24 to 48 inches between containers. 25

27 When is a nonacute hazardous waste container empty? When there s nothing in it, right? With nonacute hazardous wastes, even a small residue may present a hazard. RCRA defines a container as empty by measuring the depth of hazardous waste residue in the container or calculating the percent weight of residue left in the container. A container is considered empty if all nonacute hazardous waste has been removed that can be by common practices such as pouring, pumping, or aspirating and: There is 1 inch or less of residue on the bottom of the container or inner liner; or There is no more than 3 percent by weight of residue in a container or inner liner of 119 gallons or less; or There is no more than 0.3 percent by weight in a container or inner liner with more than 119 gallons capacity. A container that held hazardous waste compressed gas is empty only when the pressure in the container has reached atmospheric pressure. To be considered empty, containers or inner liners that held acute hazardous waste must be triple-rinsed with a suitable solvent or cleaned by another equivalent, scientifically valid method. 26

28 Containers may be reused to hold compatible wastes but should never be reused to hold incompatible wastes. Facilities should clearly define what containers can be discarded in the domestic trash versus those that must be segregated and disposed of in some other manner. Use appropriate cleaners and approved methods to clean containers. 27

29 All hazardous waste storage areas must be inspected weekly by trained inspectors. Be sure to arrange inspections even during holidays and vacations or times the facility is shut down. Although some states require generators to maintain written inspection logs, the federal regulations do not. However, a written record that can be produced, if necessary, is a prudent method of documenting that inspections have indeed been done. It is recommended that the inspection records be maintained in a secure and organized filing system for at least a year. Note that even though a generator log is optional for inspections, it is required for permitted and interim-status facilities. These facilities must keep the log for three years from the date of the inspection. 28

30 When conducting a weekly inspection of containers and the hazardous waste container storage area, check that: Each container is in good condition without evidence of rusting, corrosion, or other structural defects. Each container is made of a material that will not react with the waste so that the container s ability to contain the waste is not impaired. The container storage area is free from evidence of leaks and spills. All containers are securely closed. 29

31 When inspecting a hazardous waste container storage area, check that: Aisle space allows the easy inspection of the condition of all containers. Labels on all containers are not damaged and are readable. Labels include all required information, and There is unobstructed access by personnel and emergency equipment in the event of a fire, spill, or other emergency. 30

32 When inspecting container storage areas check that: Container storage areas have a containment system, if one is required. Accumulated precipitation is free from evidence of leaks and spills. The floor and containment systems have no cracks, gaps, or other deficiencies. Any drain valve is locked in a closed position. 31

33 When inspecting container storage areas, check that: The container is always closed while holding hazardous waste, except when necessary to add or remove hazardous waste. There is no indication that the container is opened, stored, or otherwise handled in a manner which may rupture it or cause it to leak. 32

34 When inspecting LQG containers that store ignitable or reactive waste, check that: These containers are located at least 50 feet from facility property lines. Remember that some states may allow LQGs to apply for an exemption from this restriction. Containers are protected from sources of ignition and reaction such as open flames, cutting and welding, sparks, and radiant heat. No Smoking signs are clearly visible in areas where there is a hazard from ignitable or reactive waste such as where containers are stored. 33

35 Be sure also during inspections of containers to check that: No incompatible wastes or materials are placed in the same containers. Hazardous wastes are only placed in washed, clean containers when those containers previously held incompatible waste. Incompatible hazardous wastes are separated from each other by a berm, dike, wall, or other device. 34

36 Waste minimization is a critical part of the hazardous waste management process, and one of the goals of RCRA. Waste minimization also plays a crucial role in the management of containers. Let s discuss some of the principles of waste minimization that will reduce the need for storage of hazardous wastes in containers. Always share inventories of hazardous materials with other users in your facility, if possible. This reduces hazardous materials inventory. It will also reduce the number of containers that will reach the end of their shelf lives and be thrown away. When possible, substitute less hazardous chemicals for hazardous chemicals and less regulated chemicals for those that are heavily regulated in your experiments, procedures, and processes. Select procedures that allow hazardous materials to be reused whenever it is practical and safe. Use smaller quantities of hazardous materials in your procedures, experiments, and processes. Dispose of hazardous materials promptly at the end of their shelf life unless tests show that they are still useful. 35

37 It s important that you always know what you are using or storing. The identity of items must be known before disposal. Analyzing an unknown material to identify it is usually very expensive and time-consuming. Optimize process operations to minimize the generation of hazardous waste. Transfer hazardous materials to other authorized users or dispose of them as hazardous waste if you are leaving employment. Finally, make it company practice to buy the smallest amount of material possible to minimize the disposal of unused materials. 36

38 Let s summarize the training we have just completed. Your generator classification dictates both the quantity of hazardous waste you can accumulate on-site in containers and for what length of time. Containers to store hazardous waste must be in good condition, compatible with the waste they hold, and kept closed (exceptions to the closed requirement may apply). Certain hazardous wastes must be segregated from each other in order to avoid potential explosions, fires, or other environmental emergencies. You must also handle incompatible wastes and those that are ignitable or reactive according to specified procedures to avoid similar occurrences. Proper labeling of containers and marking them with the start date will ensure that you know what you re storing and for how long. Inspecting containers and their storage areas weekly will head off unsafe conditions at your facility. Following procedures of waste minimization (such as inventory reduction) can reduce the need for storage of hazardous waste in containers. 37