Waste Compliance Refresher

Transcription

1 Waste Compliance Refresher Texas Aggregates & Concrete Association Nic Andreani, P.E. Vice President W&M Environmental Group, Inc. Austin Fort Worth Houston Plano San Antonio

2 Waste Compliance Completing Waste Determinations Generator Requirements Texas Reporting Requirements Maintaining Compliance & Minimizing Risk 2

3 Applicable Regulations EPA Federal Law and Rules (RCRA) Title 40 Code of Federal Regulations (40 CFR) Parts TCEQ State Law and Rules Title 30 Texas Administrative Code (30 TAC) Chapter 335 3

4 Completing Waste Determinations

5 5

6 What s an Industrial Facility? You have an industrial facility if you engage in any of the following activities: You make a product for wholesale according to an organized plan and with a division of labor; Change materials by processing* them; or Substantially support** either of those activities. If you are involved in any of these industrial activities, all wastes that your facility produces are industrial waste even office trash 6

7 What s an Industrial Facility? Industrial Facilities Chemical Manufacturers Electric Generating Plants Fabricated metal products facilities Mining Operations Slaughterhouses Oil and/or chemical Refineries Non-Industrial Facilities Commercial Printers Concrete Ready Mix Plants Distribution of electricity (no generation) Dry Cleaning Facilities Petroleum Distributors Meat Packaging 7

8 Identifying Your Waste From TCEQ RG-234 rev. 7/09 8

9 Universal Waste Alternative and less stringent management standards Generally applies to: Batteries Pesticides Mercury containing thermostats Lamps Paint and paint related waste (Texas only) Non-empty aerosol cans, certain electronic devices (California and Colorado) 9

10 Used Oil Used Oil Refined from crude oil or synthetic oil Does not include food grade oils Recycling presumed If disposed, then must treat as a waste Storage Good Housekeeping Drums, tanks, pipes in good condition Marked Used Oil not Waste Oil Don t mix with other wastes (especially hazardous) 10

11 Combined Waste Considerations Mixture Rule a mixture of a characteristic hazardous waste and a non-hazardous waste is non-hazardous if it no longer exhibits any hazardous waste characteristics a mixture of a listed hazardous waste and a non-hazardous waste remains the listed waste, o unless the listed waste is designated only because it exhibited ignitable, corrosive or reactive characteristics Derived-from Rule Any material derived from treatment of a listed hazardous waste is also a listed hazardous waste. 11

12 Generator Requirements

13 Types of Generators Hazardous Waste Generated (per month) Acutely Hazardous Waste Generated (per month) Generator Class Large Quantity Generator (LQG) > 2,200 lbs > 2.2 lbs Small Quantity Generator (SQG) 220 to 2,200 lbs < 2.2 lbs Conditionally Exempt SQG (CESQG) <220 lbs < 2.2 lbs 13

14 What Counts as Waste? What not to count. Non-hazardous waste Class 1 non-hazardous counts towards TCEQ registration requirements Used oil Universal Waste Managed immediately in on-site elementary neutralization unit Wastewater treatment units Totally enclosed treatment units that recycle the waste without prior storage or accumulation 14

15 15

16 Storage BMPs Label with Hazardous Waste and the contents Good condition (no leaks, rust, dents, etc.) Compatible with contents Spent ink Keep closed when not adding or removing waste Incompatible wastes are stored separately 16

17 Texas Requirements Notification of Regulated Activity Obtain state specific Solid Waste ID and EPA ID numbers Notify if SQG or LQG; or Notify if CESQG that generates > 220 lbs of Class 1 industrial waste in a calendar month Notify on TCEQ Form & EPA Obtain a Notice of Registration (NOR) Obtain TCEQ Solid Waste ID # Obtain EPA ID # 17

18 Notification Requirements Initial Notification Multiple Forms Submitted to TCEQ Updates Use STEERS 18

19 State of Texas Environmental Electronic Reporting System Create new account Industrial and Hazardous Waste (IHW) Program View and submit changes to facility and contact data View, add and submit changes to Texas waste codes and management units View, create and submit the annual waste summary and monthly waste receipt summary 19

20 20

21 One-Time Shipments One-Time Shipment (OTS) Waste Codes For industrial generators who are not and should not be registered with the TCEQ. o E.g., CESQG who generates <220 lbs/month of Class 1 non-hazardous waste Receive: o temporary Texas registration number, o temporary Texas waste code, (for one time use only), and o if necessary, a temporary EPA ID number. Complete the One-Time Shipment Request for Texas Waste Code for Shipment of Class 1, 2, 3, and EPA Hazardous Waste Form (TCEQ-0757). 21

22 22 Minimizing Your Risk

23 CESQG Record Keeping Verification of quantity and storage limitations Waste stream documentation Description of waste and generation process Waste classification determination Analytical and/or process knowledge Manifest not legally required, but a good idea EPA ID number not required Use EPA ID: TXCESQG TCEQ Solid Waste ID required if generate >220 lbs Class 1 nonhazardous waste 23

24 Typical Records Reviewed during Inspections or Audits 1. Notification of Hazardous Waste Activity (EPA ID No.) 2. Hazardous waste manifests 3. Manifest exception reports 4. Annual Waste Summary Reports 5. Inspection logs 6. Delistings 7. Land disposal restriction certifications 8. Employee training documentation 9. Hazardous substance spill control and contingency plan 10. Material Safety Data Sheets (MSDSs) 11. Inventory records 12. Shipping papers 13. Hazardous Communication Plan 14. Spill records 24

25 Staying in Compliance Designate a person in charge, and train them Keep waste characterization documents Use manifests and document your monthly waste generation Consistency Look for waste minimization opportunities Keep records current Manage your stormwater Use the Texas Audit Privilege Act 25

26 Resources TCEQ Small Business & Local Government Assistance Compliance Checklists Concrete Batch Plant Aggregate Production Fleet Maintenance many others

27 Choosing Your Waste Management Facility US Oil Recovery Superfund Site Pasadena, Texas Processed: Industrial & non-industrial wastewater Industrial waste Hazardous Waste Used Oil Municipal Solid Waste Wastes remain Impact to adjacent bayou 27

28 Questions? Nic Andreani, P.E. Vice President W&M Environmental Group, Inc. Austin Fort Worth Houston Plano San Antonio