Annual Training for Hazardous Waste Generators

Transcription

1 Annual Training for Hazardous Waste Generators Presented at AEF s April 2018 Regulated Waste Seminar By: Garrett Mikel Cantrell Rd. Little Rock, AR (501) gmikel@ecci.com

2 Arkansas Pollution Control & Ecology Commission Regulation No. 23 Hazardous Waste Management regulates active facilities Generators; Transporters; & Owners & Operators of Treatment, Storage, & Disposal facilities.

3 Annual Training Requirements Section references Section 265 (Interim TSDFs) All persons who are handling, transporting, or storing hazardous wastes must be trained within 6 months of their hire date. Prior to training, accompanied by trained personnel. Annual Refresher Courses Instruction in hazardous waste management procedures relevant to the positions in which they are employed. Contingency Plan! Records Job Title, Description, and Type, Amount, and Frequency of Training Retain on current personnel until closure of facility or 3 years from end of employment.

4 When is it a Waste Solid Waste (includes solids, liquids, & gases) When it is discarded or abandoned When it has no value Not necessarily Hazardous All Hazardous Waste is Solid Waste but not all Solid Waste is Hazardous Waste

5 When is a Solid Waste Hazardous? Process Knowledge Testing Characteristic or Listed?

6 Hazardous Waste Determination Characteristic Hazardous Waste Ignitable (D001) Corrosive (D002) Reactive (D003) Toxic (D004-D043) Based on specified tests or knowledge Process knowledge or records of analysis CAREFUL!- Must be correct & convincing Recommend keeping on-record for 3 years

7 Hazardous Waste Determination Listed Hazardous Waste Non-Specific Sources (F) Chemicals e.g. F002- Spent Tetrachloroethylene (>10% before use) Specific Sources (K) Industry/Manufacturing Processes e.g. K045- Spent carbon from the treatment of wastewater containing explosives Products that become wastes (P or U) Off-spec, residues, or contaminated materials e.g. U210- Tetrachloroethylene (Sole Active Ingredient)

8 Hazardous Waste Determination Help Federal Regulations 40 CFR 261 Subpart D Tables State Regulations APC&E Commission Regulation 23 Incorporates Federal Tables Waste Analysis/Characterization Services Third Party Waste Management or Disposal Services Generator assumes liability.

9 Notification of Regulated Hazardous Waste Activity Generating, storing, marketing, burning, transporting, or disposing of a hazardous waste Complete Form : Notification of RCRA Subtitle C Waste Activity Arkansas version available on ADEQ website Update form when facility has changes in contact information, ownership, or waste codes

10 Generator Status Conditionally Exempt Small Quantity Generators (CESQGs/VSQGs) Generate <220 pounds/month <2.2 pounds/month Acutely Hazardous (P wastes) Accumulate <2,200 pounds <2.2 pounds Acutely Hazardous

11 Generator Status Small Quantity Generators (SQGs) Generate >220 & <2,200 pounds/month <2.2 pounds/month Acutely Hazardous (P wastes) Accumulate <13,200 pounds <2.2 pounds Acutely Hazardous (P wastes) Accumulation time limited to <180 days EPA ID Number, Emergency Procedures, Recordkeeping, & Reporting Required

12 Generator Status Large Quantity Generators (LQGs) Generate >2,200 pounds/month >2.2 pounds/month Acutely Hazardous (P wastes) No Accumulation Weight Limits Accumulation time limited to <90 days EPA ID Number, Emergency Procedures + Contingency Plan, Recordkeeping, & Reporting Required

13 Accumulation & Storage of Storage Units Hazardous Waste Containers Hazardous Waste Tanks Drip Pads Containment Buildings Satellite & Central Accumulation Areas

14 Satellite Accumulation Areas Container at or near the point of generation Under the control of the operator Containers 55 gallons ( 1 quart Acutely Hazardous) Portable & DOT Approved Marked HAZARDOUS WASTE or other identifying label All Containers No Date (no time limit)

15 Satellite Accumulation Areas Containers in Good Condition No leaks or deterioration Compatible with materials being stored Closed Containers No Spills Full containers (55 gallon) must be moved to Central Accumulation Area within 3 days. Dated (after full or finished using) Moved by employee thoroughly familiar with proper waste handling procedures

16 Central Accumulation Areas Emptying Containers No more than 1 inch of remaining waste SQG 180 days Incompatible Wastes LQG 90 days Incompatible Wastes Ignitable & Reactive Wastes Kept away from ignition or reaction sources NO SMOKING signs nearby

17 Central Accumulation Areas Weekly Inspections Leaks, Corrosion, Closed Lids Labels, Dates, Containment, Emergencies, Signage, Aisle Space Qualified Inspector with Documented Training

18 Hazardous Waste Labels

19 Universal Wastes Alternative standards for Batteries, Pesticides, Mercury-Containing Equipment, Bulbs &, Consumer Electronics Universal Waste Handler Status Small Quantity Handlers of Universal Waste (SQHUW) <11,000 pounds on-site Large Quantity Handlers of Universal Waste (LQHUW) 11,000 pounds on-site

20 Universal Wastes Accumulation time limited to 1 year EPA ID Number Required for LQHUW Employee Training for Handling & Emergency Procedures No Hazardous Waste Manifest Required Labeling Universal Waste Batteries, or Waste Batteries, or Used Batteries Same for other Universal Waste

21 Universal Waste Labels

22 Waste Oil vs. Used Oil Waste Oil- Generic Term New but may or may not be contaminated by hazardous substances Unusable / No Value Not Defined in Hazardous Waste Regulation Used Oil- Precise Regulatory Term Used and may be contaminated by physical or chemical impurities May be refined and recycled / Valuable

23 Good Housekeeping

24 Bad Housekeeping

25 Safety Procedures All employees should be aware of the locations of: Emergency Plan/Procedures Emergency Telephones & Telephone Numbers Emergency Evacuation Routes & Exits Fire Alarm Pull Stations Fire Extinguishers Spill Response Kits & Materials First Aid Kits Chemical Alarms

26 Contingency Plan Each owner or operator must have a contingency plan to minimize hazards. Describes actions personnel take in response to fires, explosions, or any unplanned sudden or non-sudden release of hazardous wastes. Emergency contacts must be listed on the plan. Emergency equipment should be listed on the plan. The plan is initially submitted to all local responders. Changes to the plan must be resubmitted to each responder.

27 Transportation & Disposal Transport by a permitted Hazardous Waste transporter Hazardous Waste Manifest Shipped to a permitted Treatment, Storage, and Disposal Facility (TSDF) DOT Regulations and Restrictions

28 Return Manifests LQG Contact Transporter/Disposal Facility Within 35 Days Report Within 45 Days SQG Report Within 60 Days

29 Annual Hazardous Waste Report Due March 1 of every year to ADEQ Online using specific ADEQ reporting forms Report describes: General facility information Amount & type of hazardous waste, universal waste, & used oil generated during the previous calendar year by waste stream. Shipment information (who shipped it & who received it)

30 Summary All containers MUST be in good condition No leaks, bulging, rusting, damaged, or dented drums. All containers MUST be sealed (lids or bungs on) at all times that waste is not being added or removed. If any containers leak - place waste in new or good used empty drum or overpack. DO NOT mix different waste types or use drums that held another type of material.

31 Summary When emptying any containers, they can have no more than 1 inch of remaining waste to be considered empty. Make sure that all containers are labeled with Hazardous Waste label & that the label is complete accumulation date, facility name, waste material, description (waste codes) & other information. Satellite Accumulation point is at or near generation point. Waste containers CANNOT be stored for more time than allowed by Generator Status. Make sure that drums have enough space between them to see the labels & inspect. (3 feet between rows & stacked 2 high max).

32 Summary Inspect containers weekly & DOCUMENT!!! Hazardous waste cannot be moved from the satellite area with out being properly labeled. Hazardous waste can only be delivered to the hazardous waste storage area by trained employees. Hazardous waste must be shipped off-site with a completed Hazardous Waste Manifest. Know where the all emergency numbers, fire alarms, fire extinguishers & spill equipment are located.

33 Your Mission Annual Employee Training Requirements Specific Presentations LQG SQG Contingency Plan! Records