Hazardous Waste Being Compliant and helping the Environment

Transcription

1 Hazardous Waste Being Compliant and helping the Environment 1 Instructor Patrick Watson, CHMM ATK Sporting Group Transportation/Environmental Compliance 12+ years with Clean Harbors 2 Duration Hour and a half I COULD take ALL DAY! 3 1

2 Objective This basic class will review: Waste determination Generator/TSDF standards Accumulation area requirements Satellite accumulation area requirements 4 The Resource Conservation and Recovery Act Passed in 1976, phased in over four years Goal: To protect human health and the environment Identifies hazardous waste Mandates proper handling, storage, transport t and disposal of hazardous waste States have the right to administer States may be more stringent or broader in scope California, Minnesota, Massachusetts, Etc!!!! 5 Section 1 Hazardous Waste Identification 6 2

3 Hazardous Waste Determination Is it a waste? Is it exempt? Is it listed? Is it characteristic? Is it regulated by State? 7 Discarded Materials First, these regulations only apply to materials that are being discarded or abandoned. 8 Waste Bull s-eye Discarded Materials Solid Wastes Products used for their intended purpose are not being discarded. Hazardous Wastes 9 3

4 Solid Waste and Hazardous Waste For us to understand what hazardous waste is, we must understand the term solid waste. 10 Solid Waste Statutory Definition: Any garbage, refuse, sludge from a wastewater treatment plant, water supply treatment plant, or air pollution control facility, and other discarded material, including solid, liquid, semisolid, or contained gaseous material, resulting from industrial, commercial, mining, and agricultural operations and from community activities. AKA, the stuff you are discarding. 11 Solid Waste Regulatory Definition: Materials that are abandoned; Materials that are recycled; Materials that are inherently waste-like; and Waste military munitions. Solids Solid waste does not have to be solid Semisolids Liquids Gases 12 4

5 Solid Wastes Discarded Materials Solid Wastes Here is a drum of an out dated chemical. It can not be used, thus you want to get rid of it. Hazardous Wastes 13 Excluded From Being Solid Wastes Domestic sewage Industrial wastewater discharge regulated under the Clean Water Act Scrap metal Nuclear material regulated under the AEA of 1954 Pulping liquors that are reclaimed Spent sulfuric acid used to produce virgin sulfuric acid These are discarded, but are excluded from being solid waste 14 Excluded From Being Solid Wastes Discarded Materials Solid Wastes Lead scrap is discarded, but is not classified as solid waste since it gets recycled into new lead. Hazardous Wastes 15 5

6 Hazardous Waste Statutory Definition: A solid waste, or combination of solid waste, which because of its quantity, concentration, or physical, chemical, or infectious characteristics may (a) cause, or significantly contribute to, an increase in mortality or an increase in serious irreversible, or incapacitating reversible, illness; or (b) pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, or disposed of, or otherwise managed. Bla, bla, bla Wake me when it s over. 16 Hazardous Waste In other words, a hazardous waste is a solid waste which is hazardous (to you or the environment). There are four ways a material can be a hazardous waste. 1.Ignitable 2.Corrosive 3.Reactive 4.Toxic We will look at each one in just a minute. 17 Solid Wastes Discarded Materials Solid Wastes Here is a drum of an out dated chemical. It can not be used, thus you want to get rid of it. This chemical is an ignitable liquid. Hazardous Wastes To be classified as hazardous waste, the solid waste must be: Ignitable, Corrosive, Reactive, or Toxic 18 6

7 Excluded From Being Hazardous Wastes Household waste Mining overburden returned to the mine site Fly ash waste, bottom ash waste, etc. Industrial process wastes which fail the test for TCLP exclusively for trivalent chromium Cement kiln dust 19 Excluded From Being Hazardous Wastes Discarded Materials Solid Wastes Household waste collected by the city for safe disposal. This drum contains pool chemicals which are corrosive, but they are specifically excluded. Hazardous Wastes 20 As you see, hazardous wastes are a subset of solid wastes. Hazardous Waste Determination The generator must 1. Determine if the waste is excluded. 2. Determine if the waste is listed. 3. Determine if the waste is characteristic. 4. Finally, determine if the waste is regulated by State. This can be done by testing or applying knowledge. (M)SDS 21 7

8 Hazardous Waste Identification How do you sail around the world? How do you fly? How do you go to the moon? How do you classify hazardous a waste? This was something completely new. EPA was challenged to define hazardous waste, then regulate it. We ve already covered exclusions. 22 Hazardous Waste Identification EPA decided to go to big industry (sources) to see what wastes they produced. Organic chemical manufacturing Inorganic chemical manufacturing Explosives manufacturing Pesticide manufacturing Petroleum refining Of all the wastes they produced, EPA decided to regulate the ones that were inherently hazardous. 23 Hazardous Waste Identification EPA then decided to examine the major processes (nonspecific sources) in the US. They examined the most common chemicals used in many processes across the US. Degreasing operations Solvents Electroplating operations Again, EPA regulated the hazardous ones. 24 8

9 Hazardous Waste Identification EPA then realized that many chemicals were disposed of because they were kept past there shelf life. Many unused chemicals were being disposed of because they were outdated. Acetone Benzene Chloroform EPA decided to regulate these virgin (unused) chemicals, off-spec versions, and spills of them. 25 Hazardous Waste Identification There are over 5,000,000 known chemicals. It s common for a virgin hazardous chemical to not receive a P or U code. It s common for a hazardous process waste stream not to receive a K or F code. EPA needed to make a safety net. 26 Hazardous Waste Identification EPA then made waste classifications for materials that exhibited a hazardous property. Ignitable Corrosive Reactive Toxic These classifications acted as a safety net so hazardous chemicals would not go to non-haz landfill (and into groundwater). 27 9

10 Characteristic Hazardous Wastes D001 D002 Ignitable Corrosive D003 Reactive D004- Toxic (Specific) D Ignitable D001 Ignitable, compressed gases Liquid with flashpoint < F Solids, other than gases that, may cause fire through friction, absorption of moisture, or spontaneous chemical changes Oxidizers and organic peroxides 29 Corrosive D002 Aqueous solutions with a ph of less than or equal to 2 or greater than or equal to 12.5 Liquids which corrode steel faster than.250 inches per year Acids Neutral Bases Must contain water! 30 10

11 Reactive D003 Unstable and readily undergo violent change Can react violently with water Can form potentially explosive mixtures with water Readily capable of detonation or explosive decomposition Generally, only 1.1, 1.2 and 1.3 not 1.4S Most 5.2s do not fit the D003 definition. 31 Reactive D003 Generates toxic gases, vapors or fumes when mixed with water Cyanide or sulfide bearing waste that can produce toxic gases when mixed with ph conditions between 2 and 12.5 (Sodium cyanide, potassium cyanide, gold cyanide, lead sulfide, sodium sulfide, silver sulfide) Capable of explosion if heated under confinement DOT Forbidden Explosives 32 Toxic D004 D043 Materials that fail T.C.L.P. Testing shows if hazardous constituent can be leached out of a sample. If we put this into a non-haz landfill, could it leach harmful substances into our drinking water? 33 11

12 Toxic D004 D043 These are specific metals, pesticides, organic compounds and herbicides. Only hazardous waste if found at or above the regulatory limit. Example: Lead is only a hazardous waste if tests find the level to be 5.0 mg/liter or more. 34 State Wastes States can administer their own RCRA Programs, and can be more stringent. Minnesota has its own toxicity waste code Texas has build your own waste code. California makes it up as they go along?? 35 Identifying Hazardous Waste F codes or K codes D codes State codes P codes or U codes 36 12

13 Identifying Hazardous Waste Listed Wastes F codes or K codes Characteristic Wastes D codes State codes P codes or U codes 37 Manifesting of Hazardous Waste If a waste receives any listed or characteristic code, the material is deemed a hazardous waste. RCRA goes on to say hazardous waste must be transported on a hazardous waste manifest. Manifesting of waste is a safety specific function (hint hint) 38 Identify the waste code(s) Unused drum of Ethyl Acetate It is past its expiration date, we can t use it anymore. We ve never opened the drum. Unused = virgin = U112 DOT hazard class = 3 = D001 This material is EPA/RCRA hazardous waste with codes U112 and D001. UN1173, Waste Ethyl Acetate, 3, PGII 39 13

14 Identify the waste code(s) Copper Electroplating Solution containing copper, lead, potassium cyanide and potassium hydroxide. Spent Electroplating Waste = F006 Spent cyanide = D003 (no P-code, spent!) Lead = D008 Copper = No Codes Potassium Hydroxide (ph > 12.5) = D002 RQ, UN1935, WASTE CYANIDE SOLUTIONS, N.O.S., (POTASSIUM CYANIDE, LEAD), 6.1, PG II (D002, D003, D008, F006) 40 Identify the waste code(s) Unused bottle of lead nitrate Unused lead nitrate = no U or P codes DOT hazard class = 51=D Material contains lead = D008 This material is hazardous waste with the codes D001 and D008. UN1469, Waste Lead Nitrate, 5.1(6.1), PGII 41 Questions 42 14

15 Section 2 Generation & Accumulation 43 Hazardous Waste Generation Generator Status Determined by weight and type of waste generated Generator Max. Weight (Codes) Max. Acute (P-List) Accumulation Time Quantity Limit Large Quantity (LQG) > 1000 kg/month > 1 kg/month 90 days NONE Small Quantity (SQG) < 1000 kg/month < 1 kg/month 180 days < 3000 kg CESQG < 100 kg/month < 1 kg/month NONE < 1000 kg 44 Hazardous Waste Generation Registration Federal (US Gov): CESQG generally doesn t have to do anything SQG and LQG must register with EPA and receive an EPA ID# TSDF must be permitted. State: Good luck 45 15

16 Hazardous Waste Generation Generator Requirements Accumulation time limits Start date and Hazardous Waste must appear on container Ignitable wastes and reactive wastes must be stored at least 50 feet from property line Must always have one person on call or on premises in case of emergency Must have emergency information next to phone Biennial Reporting Required (Every 2 years) 46 Hazardous Waste Generation Generator Requirements Hazardous Waste Generation Must train all employees with proper waste handling techniques and contingency plan implementation Must review training annually Facility must have Internal communication or alarm system Telephone or two way radio Fire control equipment Spill control equipment Decontamination equipment Water at adequate volume and pressure Must be tested and maintained! 47 Hazardous Waste Generation Hazardous Waste Generation Generator Requirements Must have aisle space between containers Must have prior arrangements with Police Fire department Local response teams Emergency response contractors Equipment suppliers Hospitals Must have contingency plan & Emergency Coordinator! 48 16

17 Hazardous Waste Generation Treatment, Storage or Disposal Facility (TSDF) 1 year onsite storage of waste Requirements: Obtain/maintain appropriate permits Comply with permit requirements Ignitable, reactive wastes must be > 50ft from property line (No Smoking Signs) Comply with Generator requirements 49 Hazardous Waste Accumulation Area TSDF Ship < 1 year Large Quantity Generators Ship every 90 days Small Quantity Generators Ship every 180 days (or 270) CESQG No requirements for shipments 50 Hazardous Waste Generation Improper/Inadequate Storage Main cause of releases Store to protect human health/environment 51 17

18 52 Hazardous Waste Accumulation Area Hazardous Waste Accumulation Area (Primary) Secured Clearly posted HAZARDOUS WASTE Clearly marked boundaries Impervious surface Secondary Containment? Aisle space (what can you see?) Documented inspections 53 Hazardous Waste Accumulation Area Secondary Containment Not a Federal requirement for Gen. TSDF Requirements Impervious Surface Free of cracks & gaps Sloped Not required if palletized Storm water kept out Material removed in a timely manner 54 18

19 Hazardous Waste Accumulation Good idea or bad idea? ABC Chemical Haz Waste Accumulation Point Lake, Pond, Stream, Ditch 55 Hazardous Waste Accumulation How Good could idea it or be bad better? idea? Haz Waste Accum ABC Chemical School 56 Hazardous Waste Accumulation Fence w/signage Haz Waste Accum X X X X ABC Chemical X X X X Much Better! Bermed Blacktop 57 19

20 HAZARDOUS WASTE Hazardous Waste Accumulation Container Selection Must be in good condition Free of cracks or punctures Little or no rust No leaks Compatible with waste Capable of being tightly closed Must meet UN specifications if being shipped off site

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25 Container Selection If container condition is compromised, we must transfer materials or use salvage drum. OR Salvage Drum EPA and DOT require this. 73 Container Markings While accumulating at the generator s site, a container of hazardous waste must have, at a minimum: The words Hazardous Waste, and Accumulation start date This information is used to warn people and show compliance with the 90day/180day/1 year rule. 74 Container Markings Like these HAZARDOUS WASTE ACCUMULATION START DATE CONTENTS HANDLE WITH CARE! CONTAINS HAZARDOUS OR TOXIC WASTES 75 25

26 Container Markings Some generators apply this marking to the container rather than the minimum. This marking is required when shipping offsite. RQ, UN1268 Waste Petroleum Distillates, n.o.s. (Naptha), COMB, PG III COMB FLE 2/1/2010 Federal Cartridge 900 Ehlen Drive Anoka MN MND Ignitable, Toxic D001, D005 CH Mineral Spirits 76 Hazardous Waste Marking Requirements Hazardous Waste Warning Statement Generator's Name and Address Generator's EPA Identification Number Manifest Document Number Accumulation Start Date 77 Hazardous Waste Accumulation Isn t all this a pain? Isn t there an easier way to accumulate waste? 78 26

27 Satellite Accumulation Area (SAA) a collection of waste or waste containers at or near the point of generation and under the control of the generator Under the control of the generator does not mean you have to be standing next to it the entire time. 79 Managing a Satellite Accumulation Area UNDER THE CONTROL OF THE OPERATOR: Direct visual control or, Documented weekly inspections 80 Satellite Accumulation Area (SAA) Up to 55 gallons for non-acutely hazardous waste Up to 1 quart for acutely hazardous waste Must be from a single process Must be closed unless in use Containers should be in good condition Containers should be stored in a safe area No accumulation time limits When filled, container must be moved to storage area within 72 hours 81 27

28 Satellite Accumulation Area Waste mineral spirits are poured into an accumulation drum in the Satellite! When full, we have 3 days to move the drum to the accumulation area. The 1 year time limit begins when the container limit is reached. 82 Satellite Accumulation Marking Requirements Containers must be marked The words Hazardous Waste, or The name or description of the waste (i.e. Waste Acetone ) HAZARDOUS WASTE Mineral spirits 100 D001, D005 ACCUMULATION START DATE CONTENTS Mineral spirits HANDLE WITH CARE! CONTAINS HAZARDOUS OR TOXIC WASTES 83 Questions Questions? 84 28