Workshop H. RCRA Program Management Best Practices and the Hazardous Waste Generator Improvements Final Rule

Transcription

1 Workshop H RCRA Program Management Best Practices and the Hazardous Waste Generator Improvements Final Rule Tuesday, March 27, :15 a.m. to 12:30 p.m.

2 Biographical Information Christa Oerly Russell, Senior Engineer, Trinity Consultants Trinity Consultants, 5829 Haverford Avenue, Indianapolis, IN Christa has more than 39 years of experience in environmental compliance, regulatory permitting, solid and hazardous waste management, and in industrial coatings and cement manufacturing. Christa began her environmental career in 1979 with Missouri DNR in air permitting and expanded her regulatory experience with IDEM working predominantly in solid and hazardous waste permitting and compliance. Christa s regulatory experience was followed in 1991 by a position as corporate Manager of Environmental Affairs for an industrial coatings manufacturer and included multimedia compliance responsibilities for 26 manufacturing facilities in the U.S. and Canada. In 1998 Christa joined Lone Star Cement Company as corporate Director of Environmental Compliance with compliance responsibilities for multiple cement plants and terminals. During her time in industry, Christa was also active in numerous industry work groups, including participation on several cement industry and coatings industry association committees. Christa served for several years as a Director on the Board of the Indiana Air and Waste Management Association as Programs Committee Chair. Christa joined Schreiber Yonley & Associates (SYA) in 2004 as a Senior Engineer working primarily with air permitting and emissions control technology evaluations for the cement industry and performing multimedia audits and providing assistance with RCRA compliance. SYA became part of Trinity Consultants in 2014 Christa has a Bachelor of Science degree in Chemical Engineering from the University of Missouri. Cathy Price, Hazardous Materials & Environmental Manager Department of Environmental Health & Safety, University of Louisville 1800 Arthur Street, Louisville, KY O: C: F: cathy.price@louisville.edu Cathy has over 20 years of experience in the hazardous waste industry. She has held positions in the environmental consulting, industry, and the government sector. Since 2006, Cathy has been employed with the University of Louisville s Department of Environmental Health & Safety. She is the Hazardous Materials and Environmental Manager and oversees the collection and transportation of chemical waste, universal waste, and medical waste for over 700 laboratories and clinical areas. Additionally, she manages the day-to-day operations of the University s Federal and State RCRA Part B Permitted Hazardous Waste Storage Facility. Cathy is a Certified Hazardous Materials Manager (CHMM). She has a Bachelor s of Science degree from Eastern Kentucky University.

3 Hazardous Waste Generator Improvements Rule 27 th Annual Business & Industry s Sustainability & Environmental Health & Safety Symposium March 27, 2018 Christa Oerly Russell Senior Consultant

4 Agenda Introduction to Hazardous Waste (HW) Overview of HW Generator Categories HW Generator Improvements Rule Case Studies of HW Regulatory Update

5 Overview of HW Generator Categories

6 HW Generator Categories Generator Category Monthly HW Generation Limit Total HW On site Accumulation Limit HW On site Accum. Time Limit VSQG (formerly called CESQG) HW 100 kg (220 lb)and Acute HW 1 kg (2.2 lb) and Acute residue 100 kg 1,000 kg) (2,200 lb) N/A* SQG 100 kg< HW < 1,000 kg and Acute HW 1 kg and Acute residue 100 kg 6,000 kg (13,000 lb) 180 days maximum without permit LQG HW 1,000 kg or Acute HW > 1 kg or Acute residue > 100 kg N/A 90 days maximum without permit * Although not subject to standard on-site accumulation time limits: If a VSQG accumulates > 1 kg acute HW (or > 100 kg of cleanup residue), then all quantities of that acute HW waste must be managed according to requirements for LQGs codified in (a)- (g), including the 90-day limit. If a VSQG accumulates > 1,000 kg non-acute HW, then that waste must be managed according to requirements for SQGs codified in (b)(2)-(f), including the 180-day limit.

7 Requirements by Category (1/2) Generator Category ID all HW Streams Manifest Pre Transport Preparedness &Prevention Land Disposal Restrictions VSQG * SQG LQG * Although not subject to HW manifest requirements of 40 CFR 262 Subpart B, VSQGs must ensure that hazardous waste is delivered to a person or facility who is authorized to manage it.

8 Requirements by Category (2/2) Generator Category Manage HW in Approved Tanks, Containers, etc. RCRA Section 3010 Notification Emergency Response Coordinator Available Contingency Plan Biennial HW Report VSQG SQG * LQG ** * SQGs must manage HW in accordance with , which references the interim standards in 40 CFR (b) for ignitable, reactive, and incompatible wastes. ** LQGs must manage HW in accordance with , which references the interim standards in 40 CFR 265 for process vents, equipment leaks, tanks, surface impoundments, containers, etc.

9 Hazardous Waste Generator Improvements Rule

10 HazWaste Generator Improvements Rule Long-awaited overhaul of the hazardous waste generator rules Final Rule: November 28, FR Affected regulations 40 CFR , , , 273, 279 >60 changes to the regulations, plus about 30 technical corrections Affected entities: All hazardous waste generators (CESQG, SQG, LQG), TSDFs, Transporters All industry sectors, facility types, locations

11 Major Provisions of the Rule Reorganization Episodic Generation Consolidation of CESQG (VSQG) Waste at LQGs Ignitable and Reactive Waste Waiver Waste Determination Expectations Emergency Preparedness and Prevention Labeling Satellite Accumulation Provisions Closure Requirements Additional Changes and Clarifications

12 Reorganized Rule Structure Provision Original Citation in 40 CFR New Generator Citation in 40 CFR Definition of Generator Categories Hazardous Waste Determination and Recordkeeping , 261.5, & and (c) Generator Category 261.5(c) (e) Determination VSQG Provisions 261.5(a), (b), (f) (j), and Satellite Accumulation Area Provisions (c), , , and (a) SQG Provisions (d) (f) and LQG Provisions (a), (b), (g) (i), (m), and USEPA Identification Numbers Landfill Ban for Liquids

13 Various Minor Changes VSQG (Very Small Quantity Generator) replaces CESQG Central Accumulation Area defined Storage vs. central accumulation Central vs. satellite accumulation Miscellaneous improvements Corrections, Clarifications New definitions Deleting outdated and obsolete provisions Cumulative effect of many relatively minor changes = Potentially significant effort for generators to come into initial compliance

14 Less Stringent Provisions Episodic generators VSQG consolidation option 50-foot waiver for ignitable / reactive waste HOWEVER! Not in effect until adopted in your state States are NOT required to adopt less stringent provisions

15 Episodic Generation Episodic event Planned or unplanned activity, that does not normally occur during generator operations, resulting in an increase in the generation of hazardous wastes that exceeds the calendar month quantity limits for the generator's usual category. Planned episodic event Planned and prepared for: e.g., regular maintenance, tank cleanouts, short-term projects, and removal of excess chemical inventory Unplanned episodic event Unplanned and reasonably did not expect to occur e.g., production process upsets, product recalls, accidental spills, acts of nature such as tornado, hurricane, flood

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17 Episodic Generators Valuable option for facilities with occasional temporary surge in hazardous waste generation 40 CFR 262 Subpart L ( ) Generator can remain at existing (VSQG, SQG) category during episodic generation, with the following conditions: Notify Agency at least 30-days in advance (or within 72 hours for unplanned episode) Complete the episodic event within 60-days No extensions Only one planned episodic event per year Can petition for second (unplanned) event No more than 2 episodic events/year

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19 Episodic Generators, cont. VSQG (CESQG) must also comply with SQG waste management provisions and maintain records Obtain USEPA ID Number Use hazardous waste manifest and transporter to ship to RCRA TSDF or recycler Manage in a way that minimizes potential for accident or release Label episodic waste containers Episodic Hazardous Waste Identify hazards of contents Identify an emergency coordinator at the generator facility Maintain records

20 Episodic Generators, cont. SQG must comply with existing SQG regulations Label episodic waste containers Episodic Hazardous Waste Identify hazards of contents Use hazardous waste manifest and transporter to ship to RCRA TSDF or recycler Maintain records of episodic event CONDITIONAL! All conditions must be met to retain the episodic generation conditional management benefit If one or more conditions is not met, automatically revert to higher generator category

21 VSQG (CESQG) Consolidation Option Allows company to consolidate VSQG wastes at their own LQG facility 40 CFR (a)(5)(viii) Benefits companies with multiple locations At least one location is LQG At least one location is VSQG LQG does not need to be a permitted TSDF Must be under control of the same person, as defined under RCRA Control is the power to direct policies at the facility NOT APPLICABLE to SQGs

22 VSQG Consolidation Option VSQG Responsibilities: Mark and label containers as Hazardous Waste Indicate hazards of the contents Ship/transport in accordance with applicable regulations DOT compliance if shipped on public roadway No hazardous waste manifest required and hazardous waste transporters do not have to be used

23 VSQG Consolidation Option LQG Responsibilities (found at (f)) Notification (via Site ID Form) of participation in the program (including info for all VSQGs participating) USEPA Form recently revised Recordkeeping for each shipment Maintain for 3 years Manage consolidated waste as LQG hazardous waste Start date of accumulation = date received from VSQG Include in Biennial (Annual) Report Will include new source code

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25 Ignitable and Reactive Wastes 50-foot waiver Benefits facilities with narrow or odd-shaped properties, or with limited space for hazardous waste accumulation Current rule Ignitable and reactive wastes are prohibited from storage within 50-feet of the property line New allowance Can request site-specific waiver from the local fire authority if unable to meet the 50-foot restriction Written waiver required Agency delegates responsibility for waiver to local fire authority having jurisdiction

26 Equally or More Stringent Provisions States must adopt any provision which is more stringent than the previous version of the regulations States are not required to adopt any provisions which are neither more nor less stringent: Rule reorganization Defining central accumulation area and generator categories Mixing a non-hazardous waste with a hazardous waste Generators prohibited from sending hazardous liquids to landfills Replacing the list of specific data elements with a requirement to complete and submit all data elements in the Biennial Report Deleting Performance Track and University Laboratories XL rules Technical corrections and conforming changes to various parts of the RCRA regulations

27 Waste Determinations Must accurately document hazardous waste determinations ( (f)) Applies to SQGs and LQGs Applies at point of generation before diluted, treated, mixed, or otherwise altered Does not apply to exempted wastes (although separate recordkeeping may be required) Does not specifically apply to non-hazardous wastes (although recommended as a best management practice) Using knowledge to determine waste characteristics Moves from (c)(2) to (d)(2) Lists types of knowledge previously accepted by USEPA Specifically allows alternative tests as part of knowledge

28 LQG Contingency Plans LQG Contingency Plans must have a quick reference guide with most critical information ( (d)) Contents of quick reference guide Types/names of hazardous waste and associated hazards Estimated maximum amounts of hazardous wastes Hazardous wastes requiring unique/special treatment Map showing where hazardous wastes are generated, accumulated or treated at the facility Map of facility and surroundings to identify routes of access and evacuation Location of water supply Identification of on-site notification systems Name of emergency coordinator(s) or listed staffed position(s) and 7/24-hour emergency telephone number(s) Submit with first Contingency Plan or with first revision following effective date of the rule Emergency Coordinator contact information no longer required to include home phone number and home address

29 Emergency Preparedness & Planning Arrangements with Local Emergency Responders Must document attempts to make arrangements with responders Whether or not successful arrangements were made Regulation is flexible on the acceptable types of documentation and on the location where that documentation is retained Waiver option for facilities with on-site response capabilities Preparedness and Prevention provisions have been relocated and clarified What emergency equipment is required, and where Must address all areas where hazardous waste is generated and/or managed LQG Information at 40 CFR 262 Subpart M SQG Information at 40 CFR (b)(8)

30 Marking/Labeling Requirements Applies to all SQGs, LQGs, Transporters Label must indicate The words Hazardous Waste Identification of hazards NEW Choice of established methods: DOT, OSHA, NFPA, Add all waste codes (prior to shipment) NEW May use recognized electronic option e.g., bar codes Exception for lab packs Accumulation start date For vessels that can t be labeled (e.g., some tanks, drip pads, containment buildings) Info can be in records or logs kept at or near the location of the vessel

31 Satellite Accumulation Provisions Satellite accumulation area regulations for SQG and LQG (New section at 40 CFR ) Containerized wastes must be compatible with each other and container itself, while in satellite accumulation Three-day requirement to move containers from satellite accumulation means three calendar days Certain containers in SAA allowed to remain open under very limited circumstances When necessary for safe operations EXTREMELY limited exception Marking and labeling consistent with central accumulation areas Except date of accumulation not required until full or closed and removed Reactive waste satellite accumulation away from the point of generation no longer allowed

32 Closure Closure of all generator central accumulation units must meet closure performance standards (i.e. clean close ) Existing LQG requirement extended to container accumulation units Can defer (with appropriate notice) until full facility closure Closure requirements for LQG Container Accumulation Areas that cannot clean close Must close as landfill Place notice in operating record within 30-days after closing a unit within a facility that cannot meet closure performance standards (or notify Agency that closure performance standards have been met) Notify Agency no later than 30-days prior to closing a facility Notify Agency within 90-days after closure of a facility that cannot clean close Note that there are separate provisions for closure of a HW unit such as taking a HW tank, within a larger HW tank farm, out of service or when replacing a HW tank.

33 Other Major Provisions of the Rule Notifications and recordkeeping SQGs required to re-notify every 4 years First report: September 1, 2021 Biennial report rules updated LQG Training can use computer-based tools Keep in mind that packaged on-line training doesn t address the site-specific training requirements Method for determining accumulation time in batch and continuous flow tanks Methods for determining generator category Mixtures of solid and hazardous wastes Mixtures of acute and non-acute hazardous wastes Numerous other changes and clarifications

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35 Independent Requirements vs. Condition for Exemption 40 CFR defines independent requirement and condition for exemption 40 CFR (a) explains significance of those distinctions This clarifies long-standing USEPA policy: Violation of an independent requirement is subject to traditional enforcement paths (NOVpenaltyreturn to compliance) Noncompliance with an optional exemption condition results in full regulation as per the underlying independent requirements

36 Independent Requirements vs. Condition for Exemption Example: Fred s Fabulous Little Chemical Company, an SQG, has a spill and notifies that they will be using the episodic generator provisions Fred neglects to arrange for shipment of the episodic generated waste, and it sits at the facility for 100-days before finally being shipped off-site At day 61, the episodic generator condition (remove within 60- days) has been violated, so Fred s Fabulous Little Chemical Company reverts to being a LQG, subject to full LQG regulation At day 91, the LQG accumulation timeframe (90-days) has also been exceeded, so the facility reverts to being an unpermitted hazardous waste storage facility, subject to full TSDF regulation NOTE: Most agencies will exercise enforcement discretion unless the situation is recurrent or poses severe risk

37 Status and Implementation Final Rule published November 28, 2016 Effective date 6 months after final rule: May 30, 2017 State Implementation Authorized states must adopt all provisions more stringent than current state regulations 1-year implementation schedule (July 1, 2018) 2-year implementation if statutory change required (July 1, 2019) State effective dates could range to late 2019 Kentucky hazardous waste regulations codified under 401 KAR 39 EPA delegated oversight of hazardous waste programs in Kentucky to the Department for Environmental Protection s Division of Waste Management The updated federal rules were incorporated into Kentucky s regulations on December 7, 2017

38 Implications of the Rule? So many changes = numerous points of compliance risk Easy enforcement targets SQG quadrennial re-notifications Waste determination documentation LQG Contingency Plans Waste labeling Limited immediate impact in most states, until the rules are adopted Expect increasing differences between state programs Generators be aware of state-specific requirements For interstate transport, be aware of state-to-state differences Some states are immediately adopting/initiating certain provisions, before adopting the full rule Focus on new requirements may highlight historic compliance weaknesses at some facilities

39 Case Studies of Revised Rule

40 Episodic Generation Case (1/5) Situation: A VSQG of hazardous waste is planning to clean out its laboratory. Typically, the site generates ~50 kg/month of hazardous waste. Designating the laboratory chemicals destined for disposal as wastes will increase its monthly hazardous waste total to ~150 kg

41 Episodic Generation Case (2/5) Under previous rule, this would have triggered the site s re-designation as a SQG. Under revised rule, 40 CFR 262 Subpart L establishes a way to maintain VSQG status: Notify agency at least 30 days in advance Ship waste off-site within 60 days of start of episodic event (no extensions) Limit to one planned event per year (up to one unplanned event also allowed)

42 Episodic Generation Case (3/5) 40 CFR 262 Subpart L (cont.): Manage wastes in accordance with SQG requirements, including but not limited to: Obtain EPA ID number Satisfy container/tank requirements: Label containers/tanks with Episodic Hazardous Waste, indication of hazards, and date episodic event began Keep inventory logs/records for tanks Implement procedures to prevent tank overflow Inspect tanks once each operating day Containers must be in good condition and compatible with waste Containers must be closed, except when adding/removing waste Manage wastes to minimize fire, explosion, or release Comply with HW manifest provisions Maintain required records for 3 years

43 Episodic Generation Case (4/5) What did we forget to take into account?

44 Episodic Generation Case (4/5) Verify that none of the lab materials are Acute HW with a 1 kg limit This could trip LQG status, since there is no SQG status for Acute HW

45 VSQG Consolidation Case (1/4) Situation: A company has five (5) facilities classified as VSQGs of hazardous waste. These sites each generate buckets of liquid waste on a regular basis, which may not be sent to the landfill. This leads to costly disposal arrangements for a site that would not otherwise need to use a HW disposal facility. The company also operates a LQG in the same area.

46 VSQG Consolidation Case (2/4) Under previous rule, this liquid waste could not be sent to a LQG under the control of the same company. Under revised rule, this waste can be consolidated at the LQG facility: The LQG does not need to be a permitted TSDF No manifest required No requirement to use a HW transporter VSQG must mark and label the containers as HW and indicate the specific hazards Must transport the wastes in accordance with applicable DOT regulations if shipped on a public roadway

47 VSQG Consolidation Case (3/4) What questions did we forget to ask here?

48 VSQG Consolidation Case (4/4) Are all of the VSQGs in the same state as the LQG? Why does that matter? Not all states have adopted the Generator Improvements Rule, and states are not required to adopt the less stringent provisions. Both VSQG and LQG states must have adopted these provisions.

49 Episodic Generation and VSQG Consolidation Question: Can a VSQG generate waste under the Episodic generation provisions and then send it to a LQG under the Consolidation provisions? No, the waste generated under the episodic provisions makes the facility temporarily SQG. Only VSQG waste can be consolidated.

50 Questions? Christa Oerly Russell Senior Consultant Trinity Consultants (317)

51 RCRA Program Management Best Practices Correlational Perspectives from a Higher Ed TSDF Presenter: Cathy Price, CHMM Hazardous Material & Environmental Manager University of Louisville cathy.price@louisville.edu

52 Not a manufacturer, but we have things in common.. U of L follows same RCRA hazardous waste regulations (we did not adopt Subpart K) o Contingency Plans o HW Manifests We have multiple locations that generate HW U of L HW staff must receive training: o o o o o o Annual RCRA Training 40 Hr HAZWOPER training 8 Hr Annual OSHA HAZWOPER refresher Annual BBP Training CPR/First Aid Annual Fire Response training

53 Our challenges are similar, too Personnel turnover (Faculty transfers, students graduate, etc.) requires constant training of HW generators SAAs do not generate the exact same HW waste streams 100s HW SAA locations Sometimes faculty depart and forget to tell us Staffing shortage

54 University of Louisville 1798 established as Jefferson Seminary in Louisville 1833 Louisville Medical Institute chartered 1840 renamed Louisville College 1846 Law School added academic mission expanded to include School of Dentistry, Speed Scientific School, School of Music, and School of Social work. 1960s added Schools of Education, Justice Administration, and Urban and Public Affairs, and Nursing joined state system of higher education Today, we are a Kentucky premier, nationally recognized metropolitan research university.

55 University of Louisville: Facts & Figures Student Body 22,459 Faculty & Staff 6,872 Operating Budget $1.2 billion Endowment $719 million Grants & Contracts $147.8 million Graduation Rate 54.4% Alumni +148,000 Athletic Conference Atlantic Coast Conference ( data)

56 U of L RCRA Hazardous Waste Stats Over 700 SAAs Two LQGs Two 90 Day CAAs One VSQG One RCRA Part B TSDF

57 SAAs include Teaching labs Research labs Engineering labs Trade shops Art studios Medical clinics Dental clinics

58 LQG: Belknap Campus Belknap Campus is considered the main campus. South of downtown Louisville, just off I acres Home to seven of the 12 academic colleges. Campus proper also includes: o Papa John's Cardinal Football Stadium o Owsley B. Frazier Cardinal Softball Park o Cardinal Track o Mark & Cindy Lynn Soccer Stadium o Bass Rudd Tennis Center o Jim Patterson Baseball Stadium

59 Belknap Campus In 2017, Belknap SAAs generated over 11 tons of RCRA HW SAA areas include: Chemistry Speed School Health Clinic Fine Arts Trade Shops

60 LQG: HSC Campus East of downtown Louisville Health Sciences Center campus (HSC) is the heart of the Louisville medical center. Contains the School of Medicine, School of Nursing, School of Public Health & Information Sciences, and the School of Dentistry. Also on the campus are several specialty hospitals and numerous UofL research buildings and facilities.

61 HSC Campus In 2017, HSC SAAs generated over 6 tons of RCRA HW SAA areas include: Research labs Medical School Dental School Health Clinics Trade Shops

62 Two 90 Day CAAs Both on HSC Campus One managed by Dental School Clinic staff One managed by EHS Radiation Safety Office staff ( Hold & Decay area and mixed waste)

63 VSQG Campus: ShelbyHurst ShelbyHurst Campus 230 acres located in eastern Louisville Originally the site of the Kentucky Southern College Houses University business, offices and technology endeavors Location of the Center for Predictive Medicine Regional Biocontainment Laboratory

64 ShelbyHurst A handful of ShelbyHurst research SAAs generated < 50 lbs. of HW in 2017.

65 RCRA Permitted TSDF Named Environmental Protection Services Center Located near Belknap Campus (but not contiguous) Opened in October 1998 Construction cost approx. $1.2 million Interior dimensions approx sq.ft. o o 3,632 sq. ft. for waste storage 548 sq. ft. includes office, restroom and lab area Accepts U of L affiliated operation hazardous waste only (does not accept UofL Hospital) On site EHS FT Staff includes 1 HazMat Manager and 1 HazMat Technician

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70 EPSC Restricted access facility U of L EPSC staff required whenever other U of L personnel or outside vendors are within facility 98% of waste containers received are 5 gal sized Permitted activities include: o Bulk/blend o Stabilization o Neutralization o 365 day storage

71 Bulking/Blending Compatible waste bulked into 55 gallon drums Non Halogenated Organic Solvents Halogenated Organic Solvents Aqueous Heavy Metal Inorganic Acids (can contain metals) Inorganic Bases (can contain metals) Organic Solids Heavy Metal solids

72 Bulk/Blend Room equipped with large exhaust hood and access to in line personnel breathing air system

73 Neutralization Acids and bases only Neutralizations performed on a very limited scale, as most SAA generated acid and base waste streams have potential to contain regulated metals.

74 Stabilization Infrequent, case by case, such as: o Deactivation of NORM oxidizing compounds o Additional wetting of hydrazine compounds Typically, high hazard stabilization is performed by contracted HW disposal vendor

75 365 Day Storage Typically the EPSC is cleaned out on a semi annual basis 2017 Off Site Disposal costs (includes Non RCRA) Approx. $69K LQG campuses not contiguous, HW manifest and LDRs are completed by EPSC staff Game plan for e manifest undetermined

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77 Nine separate chemical waste storage areas RX Flammable Liquids & Solids Cylinders Metals Base/Cyanides Acute Toxics UW & PCB/ Non PCB Org Acids Non RCRA Toxic Organics Inorg Acids OX Office Lab

78 Facility Features Sloped floors to Dry Sumps

79 Facility Features Security Key access restricted to authorized EHS staff only Intrusion alarm system Exterior and Interior access doors; motion sensors

80 Facility Features Safety CO2 Suppression system for Reactive Waste Room Fire Extinguishers Class ABC and Class D

81 Facility Features Safety

82 Facility Features Safety LEL Sensor system in Bulk/Blend Room and Flammable Liquids room

83 Facility Features Safety Infrared/UV Camera in Flammable Liquid Storage Room Explosion Proof lighting and blast out walls in this room, bulk/blend room, and reactive waste storage room.

84 SAA Hazardous Waste Determinations Generators are not required to perform analytical testing to identify their wastes. They are, however, required to accurately characterize their wastes. This means they may make a hazardous waste determination by testing or applying their knowledge of the waste's chemical and physical properties as specified in regulations. Note: All waste containers are subject to review by EHS staff. If necessary, assessment of waste is conducted to ensure waste determination is accurate. (i.e. visual assessment, ph, solubility, oxidizing potential, hydrocarbon, portable IR).

85 SAA Hazardous Waste Determinations Product Label Review Product Safety Data Sheet o Section 3 Composition (new format) o Section 9 Physical & Chemical Properties Contact EHS for assistance

86 SAA Requirements Employees that work with chemicals must attend EHS Lab Safety or HazCom Training within 90 days of hire. Training must be refreshed every three years. Labs conduct periodic safety self assessments, includes management of wastes EHS staff conduct annual surveys of labs

87 SAA Waste Management: Four Ls of Chemical Hazardous Waste Management: L Lid should be secure fitting, and closed when not in use L Location. Waste container must be kept at or near the point of generation (i.e. the room waste is generated in) L Label. Waste container must be labeled with the words Hazardous Waste + Chemical constituent(s) + indication of waste hazard L Limit. An SAA cannot store more than 50 gallons of non acute HW or 1 quart of acute HW

88 SAA Waste Management: HWGIR Label Reuse of empty chemical container acceptable Ensure waste is compatible with container Rinse container with water Completely cover original label with new waste label

89 SAA Waste Management: Combining Chemical HW Acceptable to commingle compatible chemical wastes. All waste added MUST be identified List of waste contents can be on label or record sheet near the waste container.

90 SAA Waste Management: Cannot combine following wastes (container size limited to 4L/1 gal, filled to ¾ capacity) Nitric Acid solutions Hydrofluoric Acid Perchloric Acid Sodium azide solutions >5% Piranha solutions (3:1 mixture sulfuric acid, 30% hydrogen peroxide) Aqua Regia Mercury containing waste (solid and liquid) Radioactive material (Tritium, C 14, P 32, etc.)

91 SAA Waste Management: Storage Limit Cannot store more than 50 gallons or 400 lbs. of hazardous waste, this includes: Physical characteristic hazardous waste (ignitable, corrosive, reactive, TCLP), F listed, U listed toxic waste) Up to one quart (1 kg) of acutely hazardous waste (P List), i.e. cyanides, sodium azide, osmium tetroxide, etc.

92 SAA Waste Management: HPLC Process Collection bottles must be marked as Hazardous Waste followed by names of appropriate chemicals collected plus indication of waste hazard(s). Container lid must be screw type Hazardous Waste ACETONITRILE, METHANOL FLAMMABLE, TOXIC NOT ACCEPTABLE

93 SAA Waste Management: Disposal of Empty P Listed and Reactive Chemical containers If cannot be reused to collect hazardous waste, empty containers which previously held an EPA hazardous waste P Listed (highly toxic) or Reactive chemical are managed as hazardous waste for pickup by EHS.

94 SAA Waste Management: Disposal of Lecture Bottles & Aerosol Cans Unused, partially used and empty lecture bottles must be collected and submitted for EHS hazardous waste pick up Unused, partially used, and empty aerosol product cans must also be collected and submitted to DEHS for waste pick up. o Do not want personnel de valving empty cylinders or puncturing empty aerosol cans o Scrap metal recycler requires empty cylinders and empty aerosol cans to be cut in half prior to discard into scrap metal dumpster

95 SAA Waste Management: Request EHS HW Pick Up Step 1 of 3 Generator attaches EHS uniquely numbered hazardous waste label to each container

96 SAA Waste Management: Request EHS HW Pick Up Step 2 of 3 Generator submits online electronic form on the EHS website U of L Login ID required

97 SAA Waste Management: Request EHS HW Pick Up Step 3 of 3 Generator will scroll down on form to click submit button, within seconds receive an automated Thank You Reply IMPORTANT: If automated Thank You Reply not received, form did not go through. Review form and correctly complete fields required. Once corrected, resubmit form.

98 EHS Staff: Receipt of Pick Up Request Form Reviews for completeness. Enters information into computer based HazWaste Tracker (Filemaker Pro database) Prints out EPSC HW label for each container Prints out Field Work Order Completes HW Manifest and LDR

99 EHS Staff: Pick Up of HW from SAA Removal of HW from SAA usually in 1 4 days If P Listed HW is 1 qt/1 kg, pick up is next business day. Tech will have work order, HW manifest, LDR and EPSC waste container labels to attach to each waste container to be picked up. Ensures waste container is in good condition.

100 EPSC Response Vehicle EHS Official KY State vehicle used pick up chemical and hazardous waste Stocked for chemical and biological spills releases Stocked with appropriate PPE to Level B Respiratory

101 EHS Staff Pick Up of HW from SAA Tech will pack smaller containers ( 2 gal size) of same DOT class into Lab pack container EPSC Response truck will be placarded for any quantity of: o Dangerous When Wet o PIH Zone A o Toxic Gas

102 EHS Staff Receipt of SAA HW at EPSC EHS Staff will de pack lab pack containers before end of day EHS Staff will ensure waste containers are not leaking EHS Staff verify EPSC label and generator label match are correct EHS Staff place each waste container in assigned hazard storage area

103 EPSC Recordkeeping (paperwork, paperwork!) Document Length Incoming HW Manifests and LDRs CYA + 3 YEARS Lab Waste Analysis CYA + 3 YEARS EPSC Out Going HW Manifests Indefinitely and LDRs EPSC Weekly Inspections Indefinitely EPSC Daily Inspections Indefinitely EPA and State CEI Reports I indefinitely EPSC Contingency Plan Reviewed Annually LQG Contingency Plans Reviewed Annually

104 Contingency Plan Update to meet HWGIR EHS met with KY DWM Inspectors to propose plan update (SAA will be identified by All Hazards Sign ) KY DWM okay with plan if acceptable to local FD. EHS met with local FD, FD okay with update. In recently adopted HWGIR, must meet new requirements the next time we revise our Contingency Plan.

105 Contingency Plan All Hazards Door Sign Applies to any work area that uses or stores hazardous chemical/products. PI or supervisor, or authorized designee, must review chemical hazards in work area and complete and submit online All Hazards Door Sign template to EHS. EHS staff will create sign, laminate and send to work area to post on exterior door.

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107 Parting Thoughts Thank you EHS Staff live EHS Departmental Faculty and Research Staff look at the how a chemical will work in their process and may not familiarize themselves with the inherent physical and/or health hazard of the chemical. EHS must be consistent and persistent to educate chemical users. Train, reinforce, improve, and train. everyone home safely (EHS).