ENVIRONMENTAL COMPLIANCE PROGRAM

Transcription

1 Chapter 3. Waste Generation, Storage and Disposal 3.1 Management and Disposal of petroleum products: Employees who come into contact with petroleum based lubricants during routine maintenance and other activities including draining and refilling crankcase oil, hydraulic oil, transfer oil and other similar lubricants will adhere to the following: Handling of lubricants shall occur in well ventilated areas, and the employee should avoid prolonged inhalation and skin contact. PVC gloves shall be worn if extended contact is anticipated. Drums and hoses should be specific to the operation of fuel oils or petroleum related products. The use of the same hoses with various petroleum products can contaminate the product and make it useless. Handling lubricants and other petroleum products shall be treated with the same precautions as have been established for flammable liquids. An emergency spill kit shall be maintained immediately adjacent to the working area. The materials in the spill kit shall be used in emergency situations only. Inventory of the spill kit should be reviewed periodically and refilled as necessary. Fire extinguishers shall be within 25 feet of the activity, a distance of at least 50 feet shall be maintained between the maintenance activity and any source of sparks, elevated heat or open flames. There shall be no smoking within 50 feet of handling petroleum related products. Draining lubricants from machinery etc. shall not be performed within 50 feet of any storm drainage component, i.e. grates, u-drains, manhole covers etc. Draining lubricants over earthen surfaces shall not occur. Steps shall be taken to prevent spillage of lubricants onto the ground. Collection pans or containers shall be used and have sufficient capacity to accept the entire contents of the tank being drained, unless the flow of lubricant can be stopped midstream to change collection containers. Waste lubricants that are collected are to be transferred to properly labeled storage containers not later than at the end of the work shift during which the lubricants are collected. The use of the open type drum for the collection of liquid petroleum products should be strongly discouraged. Labels shall include a complete description of the container contents and date of original collection. Any lubricants that are spilled onto the ground shall be immediately recaptured using a wet-vac or by using absorbent material. The absorbent material that is saturated with petroleum products shall be placed into a storage drum and the drum should be properly labeled. All spills shall be reported to the supervisor. After any job is completed, the area of activity shall be checked for any signs of leaks or spills, and all containers and cleaning material disposed of properly. Drip pans will be placed under all unoccupied mobile equipment. The pan must be placed at the most strategic location under the equipment so to capture any leaks that may occur. The use of oil for weed, insect or road dust control, burning, dumping into sewers or drains or dumping into a landfill is prohibited. Mixing oils with hazardous waste is also prohibited. Recycling is strongly encouraged. See attachment O. Managing Used Oil Fact Sheet and attachment B. Do s and Don ts Used Oil, Transmission Fluid 3.2 Management of Used Oil Filters: Used oil filters will be stored in drums/containers clearly labeled Used Oil Filters. The drum/container shall be in good condition, able to be sealed and protected from the weather. The surface of the storage area shall be oil-impermeable. Some of the recyclers will require the draining of the oil prior to pickup (see attachment P, Do s and Don ts of Used Oil Filters and Transmission Filters). Page 1 of 6

2 3.3 Management of Petroleum Contact Water: If the PCW is non-hazardous and is not being recovered you must ensure to manifest on a nonhazardous Petroleum Contact Water (PCW) includes the following: manifest and dispose of in accordance with (4)(a)-(f). Transporting and Condensate from underground & disposing of the PCW to a pre-treatment facility (meeting the PCW management practices or a aboveground storage tanks Petroleum tank filler sump and dispenser sump water petroleum refinery etc.) that is connected to a POTW subject to section 402 or 307(b) of the Clean Water Act is recommended. Aboveground petroleum tank seal leakage water Water bottoms or drawdown water removed from petroleum storage tank systems Water that shows a visible sheen that has been in contact with product, such as spill containment, secondary containment (stormwater that displays a visible sheen contained in a spill containment and secondary containment area associated with #2 fuel oil or diesel storage tank, transportation or distribution system is not PCW) Recovered product or water in contact with product, which does not contain hazardous constituents other than petroleum, from first response actions Pumpable liquids from petroleum tank cleaning operations Materials that do not meet the definition of PCW include the following: Equipment or vehicle wash water Bilge water Separated solids from tank cleaning operations Groundwater contaminated with hazardous constituents other than PCW Wastewaters regulated or permitted The following management practices do not apply to used oil, oily waste etc. If producing PCW you must determine whether to recover product or not. If you are not recovering the product or the product contains a hazardous constituent above those produced by the product that produced the PCW or the PCW is a solid waste as determined under 40 CFR than the producer must manage the PCW accordingly. Do not mix or commingle PCW with any other material identified that does not fall under the definition for PCW. Product recovery will require the producer to have adequate knowledge of the process and documentation of the process knowledge and test results. The methods of recovery may include oil/water separators, best available technology or phase separation etc. Storage of PCW is limited to 180 days. Storage of PCW in containers or tanks that are not subject to registration must adhere to the following: 1. The storage container or tank should be compatible with the material, secured, closed, stored and handled in a safe manner and marked or labeled with the words Petroleum Contact Water. 2. The accumulation date is the date that the first drop of PCW is entered into the container/tank. 3. An inspection for leaks and deterioration of the tank or container shall be completed weekly. Storage of PCW in storage tanks that are subject to regulation must comply with those regulations. Accumulation can be recorded on site records indicting accumulation and removal dates or marked clearly on the tank with the date accumulation begins after the PCW in the storage tank has been removed. The tank shall be marked with the words Petroleum Contaminated Water. The transporter must be a hazardous waste transporter or a transporter who has received a DEP/EPA ID number ( form, intent to transport PCW). Shipping papers are necessary for each shipment of PCW (identify as Petroleum Contact Water ). Generators of product Storage capacity of less than 95,000 gallons shall maintain records of PCW related activities (3 years, files made available within 5days of request if not on site). Page 2 of 6

3 The records should contain the shipping papers, inspection records, address of transporter and receiving facility, the written statement provided to the receiving facility that the PCW does not contain levels of hazardous constituents above those found in the source of the PCW and date and volume of PCW shipped off site. 3.4 Management of Petroleum Contaminated rags, shop towels and absorbents: Rags, shop towels and absorbents are used as a means to cleanup spills, wipe down areas and clean tools and hands. The rags and shop towels should be managed properly through an industrial rag service as long as the rags and shop towels are not used to clean up hazardous waste. A container/drum should be used to collect rags and shop towels and marked/labeled with the words Contaminated Shop Towels and Rags Only. If the rags and shop towels are used to clean up a hazardous waste, that waste stream (the rags and shop towels) must be handled according to RCRA regulations (see attachment Q.). Absorbents can be used to clean up spills or to prevent spills from spreading. Re-use of absorbents is possible by squeezing out the oil and/or petroleum product (see attachment R, Do s and Don ts of absorbents). Otherwise the disposal of contaminated absorbents must be in accordance with RCRA regulations. Non-hazardous absorbents can be collected in an open type drum and disposed of as nonhazardous waste through our hazardous waste contractor (a non-hazardous manifest should be used). Hazardous absorbents must be collected in an open type drum and disposed of through our hazardous waste contractor as hazardous waste (follow RCRA requirements, see Chapter 5.). Labeling and marking the containers is very important. If hazardous, label the drum with the waste stream information and the date of the first accumulation of waste in the drum (see Chapter 5.). If non-hazardous, label drum with waste stream information. 3.5 Wash Water: Floor cleaning wastewater from garages, large storage or display areas, car wash/truck wash wastewater will not be discharged into the ground, septic tank, ditch, stream, lake, dry well or storm water pipe. Wash water can contain oil, grease, road-grime and other pollutants that may become part of the storm water discharge (hydrocarbons can raise the BOD & COD levels). Wash water that is discharged into an oil-water separator will be determined to be acceptable through a POTW permit or approved through testing to not be a problem for the sanitary system. Sludge and oil/grease that accumulates in the holding tank must be handled through a service that is licensed to transport and dispose of industrial waste. A determination of any hazardous constituents is required prior to cleaning, transportation and disposal. (see attachment S.) The following are practices that should be avoided: Performing repair work on vehicles in areas that can be reached by rain-waters Topping off and over filling fuel tanks Transferring and loading chemicals in areas that are subject to rain-water exposure 3.6 Oil-Water Separator: Oil-water separators will not be connected to storm water discharge, dry wells, septic tanks or discharged into streams, ditches or retention ponds. Sludge and oil/grease that accumulates in the holding side must be handled through a service that is licensed to transport and dispose of industrial waste. A schedule of the cleaning and maintenance should be determined. Hazardous waste will not be discharged into an oil-water separator. 3.7 Waste Tires: Waste tires must be disposed of in accordance with the waste tire rule. No person shall dispose of waste tires except at a permitted solid waste management facility or other facilities permitted by the state. No person may contract with a waste tire collector for the transportation, disposal or processing of waste tires unless the Page 3 of 6

4 collector is registered with the state. Documentation consisting of date tires are transported, quantity of tires, registration number of the collector and the name of the driver is required for the transportation of greater than or equal to 25 waste tires per month (see attachment T.). 3.8 Vehicle related maintenance, misc. wastes: Waste materials other then those discussed in 3.1 through 3.7 are: freon, lead acid batteries, radiator rinse water, solvents, paints, parts washers, spray cans, brake and carburetor cleaner and antifreeze. Attachment U has the do s and don ts of handling the materials. As discussed previously, storage of the chemicals should be in a well kept secure location, refer to chapter 1. The amount outside of a storage area should be the amount that is required for that shift s work. When ready to dispose of used materials, containers, liquids and sludges, a waste determination must be made. Chapter 4 will discuss the handling and disposal of hazardous waste. Even though you use a nonhazardous solution it may produce a hazardous sludge or liquid because of the process. 3.9 Aerosol Cans: If a used or spent aerosol can is sent for scrap metal recycling, the can and its contents are exempt from regulation. If the generator/user empties the can by spraying the contents out then the act of emptying the can may be an exempt recycling activity but the residue would be regulated if listed or exhibiting hazardous waste characteristics. To dispose of a can of aerosol as a non-hazardous waste, the can itself must not be a hazardous waste and the cans contents if emptied must not be regulated as discussed previously Building related wastes: Fluorescent lamps, tubes, mercury related items (mercury switches, thermometers); in general any person owning or operating an industrial institution or commercial facility or providing outdoor lighting for public places including street and highways, that dispenses of more than 10 spent lamps per month shall arrange for disposal in a permitted lined (Hazardous Waste) landfill or at permitted reclamation facilities (see attachment V.). Fluorescent lamps can not be incinerated (this includes medical waste incinerators and energy incinerators). Generators will be required to adhere to 40 CFR 262. Generators that manage the mercury wastes as a universal waste are not required to include the wastes when determining generator status (quantity determination). A generator covered under a reverse distribution program (manufacturer or distributor sponsored product stewardship program) for the purpose of recovering and reclaiming mercury is not required to register with the Department of Environmental Protection. Rechargeable Batteries It is illegal to discard nickel-cadmium or small sealed lead-acid rechargeable batteries or products containing such rechargeables into the trash. The prohibition is directed at all businesses, governments as well as residential. These batteries must be recycled or sent to a permitted facility. Types of batteries: Nickel Cadmium (Ni-cd), Nickel Metal Hydride (Ni-MH), Lithium Ion (Liion), small sealed lead (Pb) Bio-hazardous waste: The following materials are considered to be infectious waste: Cultures and stocks of infectious waste Human pathological waste, including blood saturated bandages, blood and IV bags and dialysis unit wastes Sharps used in human and animal care, including glassware Wastes from animals exposed to infectious agents in research Isolation waste where isolation is due to highly communicable diseases Certain unused, discarded sharps (needles, syringes and scalpel blades) Universal precautions shall be followed, assume every direct contact with body fluids is potentially infectious and requires protection from the exposed employee. All Blood-borne pathogens must be considered as part of this exposure group and the intent of the Universal Page 4 of 6

5 Precautions is to prevent employers from parenteral, mucous membrane, and non-intact skin exposures to BBP. DO NOT MIX WASTE STREAMS Storage of biomedical waste shall not exceed 30 days the start of the 30 days commences when the 1 st non-sharps item of biomedical waste is placed into the red bag or sharps container, or when a sharps container containing sharps is sealed. Indoor storage areas shall have restricted access located away from pedestrian traffic, be vermin and insect free and maintained in a sanitary condition. Outdoor storage areas must be maintained according to the indoor standard and in addition be conspicuously marked with the international biological hazard symbol and secured against vandalism and unauthorized entry. Sharp container needles and scalpel blades shall not be placed directly into double walled corrugated containers. Sharp containers shall be rigid, leak-resistant and puncture-resistant, the biological hazard symbol shall be conspicuously marked. Packages of biological waste shall remain sealed and be labeled with the International Biological hazard symbol and one of the following phrases: Infectious Waste, Biomedical Waste, Biohazard Waste. The outer container package shall be labeled with the transporter s name, address, registration number and 24 hour telephone number prior to transportation. The red plastic waste bags shall have the International Biological Hazard symbol and be labeled with the generators name and address (sharps container also). Packages of biological waste shall not be compacted to a density greater than 22 lbs/ft3. A biological waste generator who produces less than 25 pounds of biomedical waste in each 30 day period shall be exempt from all permit and fee requirements. Transport Biohazard waste with a permitted biohazard transporter. A written operating plan to manage biomedical waste shall be available for review by facility personnel and department review. The plan will include: a description of training for personnel; procedures for segregating; labeling, packaging, transporting, storing and treating biomedical waste; procedures for decontaminating biological waste spills and a contingency plan for emergencies. The plan will be updated as facility, policies or procedures change. Training of new personnel who handle biomedical waste will be conducted prior to commencement of duties. Annual refresher training will be completed. Biomedical waste management records shall be maintained for 3 years and shall be made available for review Pharmaceutical waste: Pharmaceutical materials that are unused commercial products can be hazardous; a hazard determination is warranted prior to discarding. If hazardous by definition (eg. ignitable), 40 CFR 261 or as listed and there is a reasonable expectation of the pharmaceutical waste being recycled in some way, when returned, then the waste is not a solid waste until a determination is made to discard these materials and if they are hazardous then they are a hazardous waste. It is the generator s responsibility to manage expired and unusable pharmaceuticals properly under the RCRA regulations. Do not dispose of pharmaceuticals with biohazard waste. A pharmaceutical product is considered a waste when the decision is made to discard. Outdated pharmaceuticals may be shipped as a product rather than a waste to a reverse distributor or accepted by a manufacturer with the intent to receive credit or the intent to recycle. The generator of the waste at that point when it is discarded will be either the reverse distributor or the manufacturer. Ideally if managed properly the pharmaceuticals including the samples must be determined to be either returnable or non-returnable prior to expiration. If non-returnable you must determine if the pharmaceuticals are by definition or as listed, a hazardous waste. Management of the waste is either as a hazardous or non-hazardous waste. The management of the waste and the programs required will be based on generator status (LQG, SQG and CESQG) and may include container management, emergency procedures, storage requirements, time constraints, labeling, shipping and record retention. Page 5 of 6

6 Implement an Outdate Management Program. This program should be provided by a reverse distributor who is permitted by the Department of Health. Contact the department of health for a listing of reverse distributors or contact the pharmaceutical company and make arrangements prior to receiving the first shipment. Some of the Hazardous pharmaceutical examples are ammonia and alcohol, tinctures, topical anesthetic, acids and bases, arzol silver nitrate and silver nitrate sticks, mineral and vitamin solutions, human and animal vaccines, barium sulfate suspensions, sterilized sutures, barium hydroxide, baralyne, dental amalgam, epinephrine/adrenaline, nicotine patches/sprays or chewing gum, physostigimine salicylate, coumadin/warfarin, lindane, selenium sulfide and chloroform (see attachment W.) Household Hazardous Waste Collection Facility: There are currently 2 permanent locations in Orange County that accept household hazardous waste Young Pine Road (Landfill) open Monday through Saturday from 8am to 5pm and Mcleod Road transfer station at 5000 L. B. Mcleod Road open Wednesday and Saturday from 8am to 5pm. Waste from county facilities can not be accepted through these facilities. The guidelines for these facilities are outlined in attachment XYZ. Page 6 of 6