TOP TEN HAZARDOUS WASTE VIOLATIONS
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1 TOP TEN HAZARDOUS WASTE VIOLATIONS MEDICAL FACLILTIES ARIZONA DEPARTMENT OF ENVIRONMENTAL QUALITY ; Dale Anderson, Manager Pollution Prevention Unit ;
2 The Way Things Were Municipal Landfill, Liquids Disposal Pit Along the Salt River, Circa /27/2005 ADEQ Hazardous Waste Top Ten 2
3 Common Sources of Pollutants and Wastes at Medical Facilities Pathology/Histology/Cytology Labs; solvents, acids, bases, reactive laboratory chemicals Analytical testing/therapeutic drug and poisons labs; solvents, in-organics X-ray machines - photo processing liquids and sludges Morgue Pharmacy Basements and surplus yards Shipping/receiving; Chemical warehouse/stockroom Mechanical/paint and other support shops 5/27/2005 ADEQ Hazardous Waste Top Ten 3
4 Power Plant, HVAC Grounds keeping Vehicles and Fleet management Information Technology & Computers E- waste Waste Storage Dumpsters IPA, xylene, formalin, methanol, mercury, silver 5/27/2005 ADEQ Hazardous Waste Top Ten 4
5 Common Mercury blood pressure devices - sphygmomanometers Mercury thermometers Mercury thermostats (HVAC) Fluorescent lamps Mercury Sources Other Esophageal dilators Batteries Dental Amalgam Mercury switches (boilers) 5/27/2005 ADEQ Hazardous Waste Top Ten 5
6 Mercury Sources Stains Alum Hematoxylin (Solution A) Cajal's Carbol Gentian Violet Gomori's Gogi's Gram Iodine Mercury Chloride Fixatives Mercuric Chloride B5 Carnoy-Lebrun Helly Ohlamacher Shardin Zeneker's Solution 5/27/2005 ADEQ Hazardous Waste Top Ten 6
7 Mercury Sources Reagents Camco Hitergent Immu-sal Mercuric Oxide (Stabilur Tablets) Mercury Iodide MercMury Nitrate Mercury Sulfate Mercurochrome Mercurophyline Million's Reagent Nessler's Solution Phenl Mercuric Acetate Takata's Reagent Thimerosal (Buffers, Merthiolate, Mucolex) 5/27/2005 ADEQ Hazardous Waste Top Ten 7
8 #10 - Reporting & Fees Failure to File an Annual Report of your Hazardous Waste activities Due March 1 st of each year Failure to pay all applicable Hazardous Waste Fees Registration Fee $100 SQG - $300 LQG Generation Fee $10 per ton, or $5 per ton with approved Pollution Prevention Plan Due March 1 st of each year; or as noted on invoice Call HW Data Line: /27/2005 ADEQ Hazardous Waste Top Ten 8
9 5/27/2005 ADEQ Hazardous Waste Top Ten 9
10 #9 - Satellite Containers Failure to limit to 55 gallons at each point of generation. Failure to maintain at or near each point of generation. Failure to label satellite containers with the accumulation start date, when 55 gallons has been exceeded. Failure to move excess of 55 gallons to appropriate storage area within 3 days 5/27/2005 ADEQ Hazardous Waste Top Ten 10
11 5/27/2005 ADEQ Hazardous Waste Top Ten 11
12 5/27/2005 ADEQ Hazardous Waste Top Ten 12
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14 5/27/2005 ADEQ Hazardous Waste Top Ten 14
15 #8 - Size Class Identification Failure to accurately determine your generator status. Large Quantity Generators 2200 pounds or more Small Quantity Generators More than 220 pounds and less than 2200 pounds Conditionally Exempt Small Quantity Generators 220 pounds or less 5/27/2005 ADEQ Hazardous Waste Top Ten 15
16 CESQG SQG LQG MONTHLY GENERATION RATE < 100 kg/mo < 1 kg/mo Acute 1 kg = 2.2 pounds 1 kg 1 quart, water weight < 100 kg/mo Acute, Residue, debris, soil > < 1000 kg/mo 100 kg drum, water weight > 1000 kg/mo 1000 kg = 2200 pounds or a little more than 1 ton. 5 drums, water weight MAXIMUM AMOUNT STORED < 1000 kg (Total acute plus non-acute) 5 drums, water weight < 1 kg Acute < 100 kg Acute, Residue, debris, soil < 6000 kg (Total acute plus non-acute) 29 drums, water weight < 1 kg Acute < 100 kg Acute, Residue, debris, soil NO AMOUNT LIMIT < 20,000 kg for F006 About 2 roll-offs/15 yards each; About 1 standard 44,000 pound truck load (approximate DOT weight limit for travel on highways). STORAGE TIME LIMIT NO TIME LIMIT < 180 If less than 200 miles to TSD < 270 If 200 miles or greater to TSD 30 day extension with prior approval from ADEQ < 90 days < 180 days for F006 Sludge when < 200 miles to TSD <270 days for F006 Sludge when > 200 miles to TSD 30 day extension with prior approval from ADEQ 40 CFR CFR (d)&(e) 40 CFR (a)&(b) 5/27/2005 ADEQ Hazardous Waste Top Ten 16
17 Size Class What to Count Regulated Hazardous Waste Hazardous waste in Satellite Containers. Hazardous waste in CESQG, SQG and LQG storage areas. Hazardous waste accumulated in other areas; secondary containment, improperly discharged. Counted month to month. Call HW Data Line: to maintain appropriate size class registration. 5/27/2005 ADEQ Hazardous Waste Top Ten 17
18 #7 - Training Facility staff must successfully complete training in safe handling of hazardous waste, and emergency procedures. Recommended: CESQG SQG LQG -OSHA Hazard Communication -OSHA Hazard Communication -40 CFR (d)(5) -OSHA Hazard Communication -OSHA HAZWOPER 24 hrs -40 CFR /27/2005 ADEQ Hazardous Waste Top Ten 18
19 5/27/2005 ADEQ Hazardous Waste Top Ten 19
20 5/27/2005 ADEQ Hazardous Waste Top Ten 20
21 Courtesy US Coast Guard 5/27/2005 ADEQ Hazardous Waste Top Ten 21
22 #7 - Equipment Failure to provide appropriate communication, fire control, spill control, and decontamination equipment, and water at adequate volume and pressure. 5/27/2005 ADEQ Hazardous Waste Top Ten 22
23 NIC NIC NIC NIC NIC NIC NIC NIC NIC Required Equipment testing & maintenance Is equipment selected to specifically address the: Types of chemicals / Amounts of chemicals / Building, facility type / Type of hazards presented / Site specific factors Do MSD Do MDSD s, safety plans, reference materials, or other programs require or suggest use of specific equipment? Internal communication or alarm system; immediately available; voice or signal i.e. intercom speaker, siren, fire alarm a Location: When HW is being poured, mixed or otherwise handled do all personnel have access to internal alarm system? a External communications system; immediately available at operations scene; phone or radio b Location: If only one staff while operating, do they have immediate access to external communications? b Portable fire extinguishers. A - paper B - fuels/solvents C - electrical D - metals Type: Size: Location: Pressure: Monthly inspect: Yearly refurbish date: Fire control equipment: Sprinkler systems Standpipes Hose systems NIC Special extinguishing equipment, foam, inert gas, dry chemical. ID types and amounts: Mixing and application equip. Inspect/test date/record? 5/27/2005 ADEQ Hazardous Waste Top Ten 23
24 #6 - Contingency Planning LQGs Failure to have a complete, written Contingency Plan, and implement it appropriately. SQGs Failure to have emergency information posted next to the telephone, and implement emergency procedures appropriately. 5/27/2005 ADEQ Hazardous Waste Top Ten 24
25 Contingency Plan Components Evacuation Hazard Identification Immediate Spill Reporting All Offsite spills of Hazardous Waste Any CERCLA Reportable Quantities, on or off-site Extinguishing and Containment Clean up Follow up written reports ADEQ 24 Hour Spill Line: /27/2005 ADEQ Hazardous Waste Top Ten 25
26 #5 - Illegal Disposal Failure to control, contain, cleanup and dispose of properly, any and all releases of hazardous waste. Discharge without a permit. Storage, treatment or disposal without a permit or interim status or appropriate generator status. 5/27/2005 ADEQ Hazardous Waste Top Ten 26
27 5/27/2005 ADEQ Hazardous Waste Top Ten 27
28 5/27/2005 ADEQ Hazardous Waste Top Ten 28
29 5/27/2005 ADEQ Hazardous Waste Top Ten 29
30 #4 - Potential Hazards Failure to operate and maintain the facility to minimize the possibility of fires, explosions or sudden or non-sudden releases of Hazardous Wastes to air, soil or surface water that could threaten human health or the environment. Failure to Minimize Hazards Potential fire, spill, chemical and safety hazards. 5/27/2005 ADEQ Hazardous Waste Top Ten 30
31 Maintain your structures and secondary containment. Concrete floors, sumps, trenches, berms. Maintain spill control equipment. Look for weak points in you design. Maintain fire safety equipment prevention and response. Do you comply with Fire Permit and OSHA safety codes? Electrical code and building codes?? 5/27/2005 ADEQ Hazardous Waste Top Ten 31
32 5/27/2005 ADEQ Hazardous Waste Top Ten 32
33 # 3 - Waste Determinations Failure to determine if any of your solid wastes are Hazardous Wastes Testing Characteristics Arizona Certified Laboratory By Knowledge Material Safety Data Sheets Disposal Service Waste Materials Profile Sheet Product Label and Manufacture s s Info. 5/27/2005 ADEQ Hazardous Waste Top Ten 33
34 5/27/2005 ADEQ Hazardous Waste Top Ten 34
35 WASTE DETERMINATION AND GENERATOR STATUS WASTE PRODUCING PROCESS DESCRIPTION WASTE STREAMS/WASTE TYPES FOR EACH PROCESS NAME AND EPA WASTE NUMBER WASTE DETERMIN ATION METHOD * WASTE HANDLING UNIT DESCRIPTION CONTAINER/TANK/PIL E/SPILL/ETC STORAGE/TREATMEN T/DISPOSAL UNIT STATIC OR MAXIM UM CAPAC ITY MONT HLY GENER ATION AND/O R PROCE SS RATE AMOU NT ON- SITE PROCESS DESTINATIO N DESCRIPTIO N ON- SITE/OFF- SITE TSD/RECYC LED/ETC 5/27/2005 ADEQ Hazardous Waste Top Ten 35
36 Check Out Your Waste Service Companies.. 5/27/2005 ADEQ Hazardous Waste Top Ten 36
37 #2 Keep Containers Closed Failure to keep containers of hazardous waste closed except when adding or removing waste. 5/27/2005 ADEQ Hazardous Waste Top Ten 37
38 5/27/2005 ADEQ Hazardous Waste Top Ten 38
39 5/27/2005 ADEQ Hazardous Waste Top Ten 39
40 5/27/2005 ADEQ Hazardous Waste Top Ten 40
41 5/27/2005 ADEQ Hazardous Waste Top Ten 41
42 #1 Marking Requirements Failure to mark containers with the: Words HAZARDOUS WASTE The accumulation start date; when waste is first placed in the container 5/27/2005 ADEQ Hazardous Waste Top Ten 42
43 5/27/2005 ADEQ Hazardous Waste Top Ten 43
44 5/27/2005 ADEQ Hazardous Waste Top Ten 44
45 Maintaining Compliance Things To Do Inspect Your Facility Inventory Your Materials, Structures, & their State of Repair Respond to Problems Use an Inspection Checklist/Schedule Create an Environmental Calendar for due dates and records Initiate Pollution Prevention Establish an Environmental Management System 5/27/2005 ADEQ Hazardous Waste Top Ten 45
46 5/27/2005 ADEQ Hazardous Waste Top Ten 46
47 5/27/2005 ADEQ Hazardous Waste Top Ten 47
48 5/27/2005 ADEQ Hazardous Waste Top Ten 48
49 Ask Questions; Ask for Help Participate in Professional Associations ADEQ ; Hazardous Waste Data HW Inspections and Compliance Unit EPA Hazardous Waste (RCRA) Orientation Manual Compliance Assistance Clearinghouse Industry and Government Sectors: Health Care Hospitals for a Healthy Environment: Pollution Prevention Resource Exchange; Medical Hub 5/27/2005 ADEQ Hazardous Waste Top Ten 49
50 5/27/2005 ADEQ Hazardous Waste Top Ten 50
Top Ten Hazardous Waste Violations. This presentation is funded in part by a grant from the U.S. Environmental Protection Agency
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