August 11, Hazardous Waste Management

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1 August 11, 2016 Hazardous Waste Management ENVIRONMENTAL ENGINEERING ENGINEERING COMPLIANCE COMPLIANCE

2 Agenda Introduction to RCRA What wastes are hazardous Waste management Generators Treatment, Storage and Disposal Facilities (TSDF) Department of Transportation (DOT) requirements Recordkeeping and reporting Examples of compliance situations EBA Hazardous Waste Management 2

3 INTRODUCTION TO RCRA EBA Hazardous Waste Management 3

4 Resource Conservation and Recovery Act Passed by Congress in 1976 with the main goals of: Protecting human health and the environment from the potential hazards of waste disposal Conserving energy and natural resources Reducing the amount of waste generated Ensuring that wastes are managed in an environmentally-sound manner RCRA includes three main programs: Solid waste program (non-hazardous industrial solid waste and municipal solid waste) Hazardous waste program Underground storage tanks program EBA Hazardous Waste Management 4

management Clean Water Act (CWA) Waste down

5 Waste Regulations RCRA Hazardous Waste Solid Waste (can be liquid, solid, gas) Conduct waste determination and manage waste accordingly cradle to grave management Clean Water Act (CWA) Waste down the drain Toxic Substance Control Act (TSCA) PCB waste State Regulations Medical/Biohazardous waste Industrial Waste EBA Hazardous Waste Management 5

6 WHAT WASTES ARE HAZARDOUS EBA Hazardous Waste Management 6

7 Hazardous Waste Waste Stream Determination A person who generates a solid waste must determine if that waste is a hazardous waste using the following method First determine if the waste is excluded (40 CFR 261.4)] Then determine if the waste is listed (40 CFR 261 Subpart D) Then determine if the waste is characteristic (40 CFR 261 Subpart C) by Testing User knowledge This is called a waste stream determination and is the first step to manage cradle to grave liability EBA Hazardous Waste Management 7

8 Hazardous Waste Waste Stream Determination Listed Hazardous Waste F list manufacturing process waste K list specific waste from specific industries P lists acutely hazardous discarded commercial chemical products U list discarded commercial chemical products Characteristic Hazardous Waste Ignitable (D001) Corrosive (D002) Reactive (D003) Toxic (D004 D043) Mixture Rule Derived From Rule EBA Hazardous Waste Management 8

9 Examples of Hazardous Waste EPA Waste Code F003 Por U listed D001 D002 D004 D043 Examples Used acetone and other solvents Unused chemicals/products resulting from inventory clean out Used oil/solvent based paints Alcohols Aerosols Strong Acids/ strong bases Sludges Mercury equipment E waste EBA Hazardous Waste Management 9

10 WASTE MANAGEMENT EBA Hazardous Waste Management 10

11 Hazardous Waste Generator Status Determination How you manage your waste depends on your generator status There are 3 Waste Generator Categories: Conditionally Exempt Small Quantity Generator (CESQG) Proposed to be renamed to Very Small Quantity Generator (VSQG) Small Quantity Generator (SQG) Large Quantity Generator (LQG) Status is based on 2 factors: Generation Rate per Month Accumulated Amount on Site Note: a non-generator and a CESQG is not the same. EBA Hazardous Waste Management 11

12 Haz Waste Generated per Month Acute Hazardous Waste Generated per month Generator Status On site accumulation of Haz Waste On Site accumulation of Acute Hazardous Waste CESQG <220 lbs/mo <2.2 lbs/mo <2,200 lbs <2.2 lbs SQG >220 lb/mo <2,220 lbs/mo <2.2. lbs/mo <13,200 lbs <2.2 lbs LQG > 2,200 lb/mo > 2.2 lb/mo N/A >2.2 lbs EBA Hazardous Waste Management 12

13 Requirements for Hazardous Waste Management All Generators Conduct and document waste stream determinations Dispose waste in accordance to the waste determination Maintain waste generation/accumulation rates Ensure waste is delivered to a licensed treatment, storage and disposal facility (TSDF) via licensed hauler Maintain waste shipping papers (manifests) EBA Hazardous Waste Management 13

14 Requirements for Hazardous Waste Management SQG/LQG Accumulate waste in closed and labeled containers Accumulate waste in appropriate containers Inspect waste containers/areas Ensure training/awareness of appropriate personnel Maintain state required recordkeeping/reporting Prepare for and prevent emergency situations Dispose within required time frames EBA Hazardous Waste Management 14

15 Treatment, Storage and Disposal Facilities Only authorized (permitted) facilities may transport, store, treat and dispose of hazardous waste Uniform hazardous waste manifest used to track movement and treatment methods of hazardous waste Land disposal restrictions are placed on waste exhibiting certain characteristics Cradle to grave generator is always responsible for final disposition EBA Hazardous Waste Management 15

16 A Note About Recycling Some forms of recycling can exempt you from the majority of the hazardous waste rules others will not Recycling must be legitimate recycling as defined in 40 CFR Avoid Sham recycling Documentation of recycling should include Date of recycling What was recycled Waste determination with regulatory citation of exclusion Where it was recycled What the recycling company does with the material to prove legitimacy EBA Hazardous Waste Management 16

17 Department of Transportation (DOT) All hazardous wastes are DOT hazardous materials Generator (shipper) responsible for: Proper packaging, labeling and marking waste containers for shipment as well as the provisions of placards where required Preparation of shipping papers (Uniform Hazardous Waste) Provisions for emergency response Training and competency of any personnel involved in process EBA Hazardous Waste Management 17

18 RECORDKEEPING AND REPORTING EBA Hazardous Waste Management 18

19 Recordkeeping and Reporting Recordkeeping Documented waste stream determinations including lab analysis and user knowledge information Generator and return copy of manifest Inspections and training records Reporting/Notification Upon initiating regulated waste activity, notification required with state environmental agency DOT registration and fees are required if shipping threshold amounts of hazardous materials Reporting varies by state but at a minimum LQG report every other year EBA Hazardous Waste Management 19

20 EXAMPLES OF COMPLIANCE SITUATIONS EBA Hazardous Waste Management 20

21 Compliance Situation #1 College was donated property and took title No environmental site assessment was completed Dozens of drums were abandoned at the site, one was fuming Question Who is the generator? EBA Hazardous Waste Management 21

22 Compliance Situation #2 Environmental site assessment was completed on a warehouse Warehouse originally identified as being used only as an off-site warehouse for a shoe company Drums were identified within the warehouse Upon further look, drums had hazardous waste labels, not chemical product labels Upon further look, waste labels identified different generators of various wastes Question What is potentially the issue? EBA Hazardous Waste Management 22

23 Compliance Situation #2 Example Waste Label Example Product Label EBA Hazardous Waste Management 23

24 Compliance Situation #3 EPA has recently been auditing TSDF and reviewing records (manifests) Based on manifest review, EPA is initiating information requests of generators that appear to be small or large quantity generator but do not have an EPA ID no. or are not identified as the correct generator In some cases, information request are resulting in stiff penalties Question How are your records? EBA Hazardous Waste Management 24

Summary Additional information available at: https://www.epa.

25 Summary Additional information available at: Check state requirements as well EBA Hazardous Waste Management 25

26 QUESTIONS EBA Hazardous Waste Management 26

27 THANK YOU. Jackie Baxley, PE Corporate Director of EHS HRP Associates, Inc 1327 Miller Road, Suite D Greenville, SC jackie.baxley@hrpassociates.com EBA Hazardous Waste Management

Hazardous Waste Generator Improvements Final Rule. US EPA Office of Resource Conservation and Recovery

Hazardous Waste Generator Improvements Final Rule US EPA Office of Resource Conservation and Recovery 2 Questions during this Webinar We expect to have time at the end of the presentation for questions