Environmental Site Assessment

Transcription

1 Environmental Site Assessment Hazardous Waste Facility Texas A&M University 2655 Dairy Center Road College Station, Brazos County, Texas October 23, 2014 Prepared for: Dr. Heather Wilkinson-BESC 411 Texas A&M University, Professor Prepared by: Chastity Smith Texas A&M University, BESC Student

2 ENVIRONMENTAL SITE ASSESSMENT TEXAS A&M HAZARDOUS WASTE FACILITY COLLEGE STATION, TEXAS Site Ownership Based on a review of information obtained from the Brazos County assessor s records, the current site owner is Texas A&M University. 1.0 SITE OVERVIEW On October 23rd Dr. Wilkinson alongside David Rice lead a visit and tour accompanied by environmental students to Texas A&M s Hazardous Waste Facility located in College Station, TX, 2655 Dairy Center Road. The primary function of this facility as a Large Quantity Generator is to collect, sort, keep record of, and to transport all hazardous waste collected from the University from cradle to grave complying with all regulations of the Texas Commission Environmental Quality (TCEQ),Environmental Health Agency(EPA),and Texas A&M s Environmental Waste Management Program. (5) (2)The manifest allows for any one taking part in the care of the hazardous waste management to track the movement for the LQG to the disposal site.(4) During the tour David Rice stated that this facility was in fact a Large Quantity Generator producing 2200 lb. or more of hazardous waste per month therefore, it is a large quantity generator and must adhere to certain requirements. LQGs are subject to regulations contained in 40 CFR Part 262 that require each generator to identify and count waste and obtain an EPA ID number (see RCRA & HW slides & EPA website) This a hazardous waste facility however, here they do not actually do the disposing of the material at this particular site. (1) Hazardous waste is defined as waste that poses a substantial present or potential hazard to human health or the environment when improperly treated,stored,transported,disposed of,or otherwise managed. (1) Pollution can come into risk only if there is a combustion or fire that could possibly happen onsite. This is because the facility holds flammable, combustable, toxic, and corrosive materials that could leak or combust at any time and pollute the surrounding area. Hazardous waste is known to cause harm are be highly reactive. Incinerators are associated with decreasing pollution as well however, this is not done on this particular site. Incinerators

3 along with BIF s are responsible for burning hazardous waste for disposal and various other reasons such as energy and recovery material. These both are governed by RCRA regulations (1 & 2) in order to reduce or omit pollution. On site the first step is collection. Employees go to various parts of campus and collect the hazardous waste. Next, the Universal waste is sorted out. Universal waste as described by Mr. Rice is the hazardous waste most commonly held by everyone. This includes: Fluorescent light bulbs and tubes, batteries, paint and all paint waste, drop clothes, brushes, switch trailers, etc. These are all treated the same and are allowed to accumulate up to a year. Some Universal Waste can then be recycled. ((5)DAVID RICE). The remaining hazardous waste is then sorted by characteristics from their boxes.(3)(2) The Hazardous Waste facility receives many different types of chemical waste both labeled and unlabeled. If the waste is unlabeled on site testing is performed in order to place the waste properly. These include: Flame testing and PH, is it an oxidizer, Is it flammable, inorganic,organic, acid, or base. The Bay room (PICTURES 3-21) was the first visited division room. Hazardous waste are determined to be in fact hazardous by their characteristics. It divides the chemicals into 4 parts based on similar behaviors and then into subparts. (5) These divisions included: 1. Flammables (SEE PICTURES 5) a) chlorinated b) non-chlorinated 2. Toxics (SEE PICTURE 4) a) Acute Poisons Classifications of Hazardous Chemical Wastes: b) Mercury - even though it is inorganic must be separated from other corrosives c) Dioxins 3. Corrosives (SEE PICTURE 8) a) Inorganic oxidizers b)hydroxides C)inorganic acids/bases d)inorganic/organic poisons 5.Universal Waste: a)batteries b)fluorescent bulbs c) paint or paint related 4. Reactives (SEE PICTURE 12) The facility then puts like chemicals into containers such as drums, a process referred to as consolidation, or lab packs for transport. It costs much less to consolidate like chemicals in order to save time of those responsible for disposal of the hazardous waste. The team at the facility follow strict guidelines with descriptions in order to mix chemicals properly. The chemicals are then tagged using the TOT process for labeling to convey dangers so the

4 responders will be aware. They are also logged into the computer system. This in order to be able to track the waste from cradle to grave. It only becomes a hazardous waste product once the facility determines it to be and it is tagged. The only thing that is kept in the Bay room are those things that the facility cannot take care of. The next room visited is referred to as Bay Room part 2. This is the room where the division is done and drums are held. After chemicals are unloaded they are put into the Segregation Process area (SEE PICTURE #) and then divided up and stamped. The certified employees then suit up and Drum the material. The facility then has 90days to ship the Drum to its proper manifest and the contractor will then send back the information regarding its disposal. The Bay Room pt 2 areas of Include: 1.The Segregation Process Area : (SEE PICTURE 14) The separation of hazardous waste takes place 2.Consolidation Process Area (SEE PICTURE 15) The mixing of similar characteristic wastes happens here 3. Flammable Liquids (SEE PICTURE 16) All flammable liquid containing drums are stored in this area 4.Hazardous Waste Container storage (SEE PICTURE 17) 5. Used Oil (SEE PICTURE 18) Oil is seen as a commodity and is stored here (Under Railroad Commission not RCRA) 6. Non-hazardous waste (See Picture 19) Office supplies and anything that is not apart of the hazardous waste. There are many processes and regulations in place to reduce pollution and waste minimization that must comply with the HSWA 1984 Hazardous Waste Amendment such as different safety structures being implemented such as: 1. Fume Hood (SEE PICTURE 6) 2. Building Built with Bricks in a row These Bricks are built straight up and down to make them weaker and the building less pressure in case of an explosion 3. Emergency Plan and a Business Contingency Plan to continue work if building burns 4 Consolidation process and recycling of the things that can be reused and recycled such as glass containers 5. one-pass ventilation system (SEE PICTURE 11) 2.0 PERMITS & REGULATIONS Under the Resource Conservation and Recovery Act (RCRA) the EPA has control as stated above to control the hazardous waste from cradle-to-grave. Cradle-to-Grave encompasses the processes generation, transport, treatment,storage, and disposal. To do so RCRA has a management blueprint for non-hazardous waste as well.(5)

5 The Hazardous Waste Facility must comply with the CWA and CAA for a Large Quantity Generator (4) and Secondary Containment - The EPA has four tools put into place to guarantee compliance to federal guidelines. The first tool is to withhold any technical assistance or federal funding. The second tool is Injunctive relief in cases of imminent threat to health or environment. (RCRA & HW slides) The third tool is enforce hazardous waste authority. (RCRA & HW slides) The fourth tool is citizens suits against EPA for failure to require the plan. (RCRA & HW slides) -The Hazardous Waste Facility must comply with Amendment Subpart K. The Federal Hazardous and Waste Amendments (HSWA) of 1984 implemented stricter hazardous waste management standards and waste minimizations and disposal to RCRA. The HSWA also requires a solid waste management plan that is implemented by each state to promote resource conservation. This plan contains the requirements in the permit for any of the accepted hazardous wastes (RCRA & HW PWPT) -which makes adjustments written for Universities rather than Industry - The Hazardous landfills implement standards for the protection of human health and sustainability of our environment. -Soil testing is performed every 6months(5) -This facility receives about 4000 items a quarter and have moved about 1900 items in the past months and serves Approximately 50,000 students including labs (5) They must strictly follow the Waste analysis procedures. TRAININGS: -Employee Training include the HAZMAT. Must do the 4 clip trainings and get certified. HAZMAT - 40hr HAZWOPPER Training CHMM- must continue education and training -The Hazardous Waste Facility is audited by several agencies listed below: DOT (Department of Transportations at 49 CRF Parts 172,173,178,and 179) for proper packaging and labeling during transport (4) EPA TCEQ Department of Public Health ATF 3.0 SITE PHOTOS

6 PHOTO 1 PHOTO 2 David Rice was the site M a n a g e r o f This is a outside view of t h e facility. the Hazardous Waste Facility.

7 PHOTO 3 PHOTO 4 This is safety sign the Eye wash This is the Bay Room Toxic division. and shower station PHOTO 5 for PHOTO 6 This is the Bay Room Flammable division. This is the Fume Hood located

8 in the Bay Room. PHOTO 7 PHOTO 8 This is the Bay Room Eye Wash station This is the Bay Room Caustic Corrosive division.

9 PHOTO 9 This is David Rice holding tagged hazardous material PHOTO 11 This is the one passageway Air Vent located in the Bay Room PHOTO 10 This is a flammable cabinet located in the Bay Room.

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11 PHOTO 13 PHOTO 12 This is the Bay Room Mercury Debris These are explosive proof division lights located in the building. PHOTO 14 PHOTO 15 This is the Consolidation

12 This is the second part to the Bay Room Process area in the Bay Room. and the Segregation Process Area. PHOTO 16 PHOTO 17 This is where the Flammable filled This is the Hazardous Waste container liquid Drums are placed. storage area. PHOTO 18 PHOTO 19 These are Drums filled with used oil ready to be transported. This section of the Bay Room is sectioned for non-hazardous waste. PHOTO 20 PHOTO 21

13 S a f e t y guidance tape marks and sections the These are tagged drums path of the Bay room into specific areas. PHOTO 22 PHOTO 23 The Back door of the facility photo of the facilities back located in the Bay Room. T h i s i s a

14 also contains safety signs. up generator in case of an electric outage. PHOTO 24 The land has a bump and a slump to hold the rain. 4.0 LQG VS. SQG COMPARISON

15 In the 1980 s the only generators that were monitored were the Large Quantity Generators because these were the big generating companies that could cause the must environmental and human health risks. Later Small Quantity Generators began to be also regulated but under different conditions. A generator according to The Hazardous Waste management handbook to include any person, by site, who first creates or produces a hazardous waste or first brings a hazardous waste into the RCRA Subtitle C system (5) LQG collect approximately 1,000kg or more of hazardous waste per calendar year,while SQG generate between 100kg and 1000kg per month and accumulate less than 6000kg of hazardous waste at a time. Some states base regulations on the volume of the generators while others distinguish them based on waste types. LQGs and SQGs both follow regulations upheld in 40 CRF Part 262. (5) One key difference between the two is also that LQGs have 90 days or less to accumulate hazardous waste while SQG are allowed to store waste for 180 or 270 if recycled by the state or EPA. At the Texas A&M facility which is a LQG they had to have personnel as an emergency coordinator and keep emergency equipment prepared and up date. They also have to have a written contingency plan unlike SQGs. Employees on LQGs sites must be trained and have HAZWOPER training while SQG employees must only be familiar with handling hazardous product. These are only two of the three volume type generators. (5) Read reference 5 the handbook to Hazardous Waste Management for more information.

16 5.0 REFERENCES 1.RCRA & Hazardous Waste Slides 2.Texas A&M Hazardous Chemical Waste Management Program Packet 3. U.S. Environmental Protection Agency 4. Texas Commission on Environmental Quality 5. Hazardous Waste Management Handbook Herndon, Christine. Environmental Compliance Guidebook. : American Water Works Assoc.,. p 19 Copyright American Water Works Assoc... All rights reserved. May not be reproduced in any form without permission from the publisher, except fair uses permitted under U.S. or applicable copyright law. 5. David Rice Texas A&M Hazardous Waste Facility Site Manager (personal tour and notes)