Top Ten Hazardous Waste Violations. This presentation is funded in part by a grant from the U.S. Environmental Protection Agency

Transcription

1 Top Ten Hazardous Waste Violations This presentation is funded in part by a grant from the U.S. Environmental Protection Agency

2 The Way Things Were Municipal Landfill, Liquids Disposal Pit Along the Salt River, Circa 1980

3 What Are Hazardous Wastes? Listed Hazardous Waste Non-specific sources Specific sources Acutely Toxic Toxic Characteristic Waste Ignitable Corrosive Reactive TCLP Toxic Exemptions? Exempt from What? Exclusion from Definition of Solid Waste Exclusion from Definition of Hazardous Waste Exempt Hazardous Wastes Recycling/Fuels as fuels/ Waste Oil/Variances/Universal waste/cesqg

4 Common Hazardous Waste Auto and Vehicle Repair Parts cleaning and degreasing solvents mineral spirits, petroleum naphtha, petroleum distillates, Stoddard solvent - D001, D008 Dry Cleaning Perchloroethylene solvent - still residues and filters D039, F002 Photo processing silver fixer liquids D011 Metal Electroplating and Circuit boards acids, bases, wastewater treatment sludges D002, F006 Metal cleaning, finishing and painting, paint gun cleaning and flammable waste paint, methyl ethyl ketone, toluene D001, F005 Furniture refinishing and painting, paint removing solvents petroleum distillates, lacquer thinner, D001, F001-F005

5 Common Hazardous Wastes Printing, ink cleaning ethanol, isopropyl alcohol, D001 Laboratories at schools, hospitals and industry acids, flammables, solvents, toxics and out of date chemicals, variety of characteristic and listed hazardous waste Fiberglass and Cultured Marble flammable solvent, acetone, D001 Mining and Mineral Processing sulfuric acid, cyanide, explosives, toxic metals mercury/lead, D002, D003, D008 Explosives excavation/construction, military munitions, improvised bombs, fireworks, wastewater sludges,d003, K044, P015 Fuels when disposed gasoline and other flammables, D001, D016 Pesticides, when disposed lindane, pentachlorophenol, parathion, 2,4-D, toxaphene, DDT D013, U129, P071

6 Common Sources of Hazardous Wastes Where Do Inspectors Look? Sewers and sewer connections Sewer interceptors and settling tanks Industrial waste pumping trucks Pretreatment plants Sinks/plumbing Septic tanks and leach fields Dry wells Storm sewers/drains Sumps, trenches, floor drains Pipelines, product and waste Transportation vehicles, trucks, forklifts, rail tankers Loading/unloading areas, truck docks, rail spurs

7 Processing floors, equipment, etc. Warehouses, chemical feedstock and product storage Drums and containers Concrete containment pads Tanks, tank farms, product and waste Ponds, pits, lagoon, impoundments Land application Landfills, open dumps Bone-yards, scrap yards, salvage yards Dumpsters, waste haulers and landfills Trenches, ditches, canals, irrigation channels Storm water retention basins Natural drainage features, washes, streams Grounds, soils, back-doors, etc.

8 #10 - Reporting Failure to File an Annual Report of your Hazardous Waste activities; Due March 1 st of each year Failure to File copies of Hazardous Waste Manifests; Due within 45 days of the end of the month of shipment.

9 #9 - Satellite Containers Failure to limit to 55 gallons at each point of generation Failure to maintain at or near each point of generation Failure to label satellite containers with the accumulation start date, when 55 gallons has been exceeded Failure to move excess of 55 gallons to appropriate storage area within 3 days

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14 #8 - Size Class Identification Failure to accurately determine your generator status Large Quantity Generators 2,200 pounds or more Small Quantity Generators More than 220 pounds and less than 2,200 pounds Conditionally Exempt Small Quantity Generators 220 pounds or less Acutely Toxic > 2.2 pounds = LQG, or > 220 pounds residue, soil, debris

15 CESQG SQG LQG MONTHLY GENERATION RATE < 100 kg/mo < 1 kg/mo Acute 1 kg = 2.2 pounds 1 kg 1 quart, water weight < 100 kg/mo Acute, Residue, debris, soil > < 1000 kg/mo 100 kg drum, water weight > 1000 kg/mo 1000 kg = 2200 pounds or a little more than 1 ton. 5 drums, water weight MAXIMUM AMOUNT STORED < 1000 kg (Total acute plus non-acute) 5 drums, water weight < 1 kg Acute < 100 kg Acute, Residue, debris, soil < 6000 kg (Total acute plus non-acute) 29 drums, water weight < 1 kg Acute < 100 kg Acute, Residue, debris, soil NO AMOUNT LIMIT < 20,000 kg for F006 About 2 roll-offs/15 yards each; About 1 standard 44,000 pound truck load (approximate DOT weight limit for travel on highways). STORAGE TIME LIMIT NO TIME LIMIT < 180 If less than 200 miles to TSD < 270 If 200 miles or greater to TSD 30 day extension with prior approval from ADEQ < 90 days < 180 days for F006 Sludge when < 200 miles to TSD <270 days for F006 Sludge when > 200 miles to TSD 30 day extension with prior approval from ADEQ 40 CFR CFR (d)&(e) 40 CFR (a)&(b)

16 Size Class What to Count? Regulated Hazardous Waste; non-exempt Hazardous waste in Satellite Containers Batch Tolling hazardous waste Hazardous waste in CESQG, SQG and LQG storage areas Hazardous waste accumulated in other areas; secondary containment, improperly discharged Counted month to month

17 #7 - Training LQG facility staff must successfully complete training in safe handling of hazardous waste, and emergency procedures. SQG staff must be thoroughly familiar. Recommended: CESQG -OSHA Hazard Communication SQG -OSHA Hazard Communication -40 CFR (d)(5) LQG -OSHA Hazard Communication -OSHA HAZWOPER 24 hrs -40 CFR

18 On-the-job, or In the Classroom

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20 Courtesy US Coast Guard

21 #7 - Equipment Failure to provide appropriate communication, fire control, spill control, and decontamination equipment, and water at adequate volume and pressure.

22 NIC Required Equipment testing & maintenance NIC NIC NIC NIC NIC NIC NIC Is equipment selected to specifically address the: Types of chemicals / Amounts of chemicals / Building, facility type / Type of hazards presented / Site specific factors Do MSD Do MDSD s, safety plans, reference materials, or other programs require or suggest use of specific equipment? Internal communication or alarm system; immediately available; voice or signal i.e. intercom speaker, siren, fire alarm a Location: When HW is being poured, mixed or otherwise handled do all personnel have access to internal alarm system? a External communications system; immediately available at operations scene; phone or radio b Location: If only one staff while operating, do they have immediate access to external communications? b Portable fire extinguishers. A paper B - fuels/solvents C electrical D - metals Type: Size: Location: Pressure: Monthly inspect: Yearly refurbish date: NIC Fire control equipment: Sprinkler systems Standpipes Hose systems NIC Special extinguishing equipment, foam, inert gas, dry chemical. ID types and amounts: Mixing and application equip. Inspect/test date/record?

23 #6 - Contingency Planning LQG s Failure to have a complete, written Contingency Plan, and implement it appropriately SQG s Failure to have emergency information posted next to the telephone, and implement emergency procedures appropriately

24 Contingency Plan Components Evacuation Plan Hazard Identification Immediate Spill Reporting All Offsite spills of Hazardous Waste Any CERCLA Reportable Quantities, on or off-site Extinguishing and Containment Clean up Follow up written reports

25 #5 - Illegal Disposal Failure to control, contain, cleanup and dispose of properly, any and all releases of hazardous waste Discharge without a permit Storage, treatment or disposal without a permit or interim status or appropriate generator status

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29 #4 - Potential Hazards Failure to operate and maintain the facility to minimize the possibility of fires, explosions or sudden or non-sudden releases of Hazardous Wastes to air, soil or surface water that could threaten human health or the environment Failure to Minimize Hazards Potential fire, spill, chemical and safety hazards

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31 Controlling Potential Hazards Maintain your structures and secondary containment Look for weak points in your design. Concrete floors, sumps, trenches, berms: Clean, Inspect, Repair Maintain spill control equipment Maintain fire safety equipment prevention and response equipment Do you comply with Fire Permit and OSHA safety codes? Electrical code and building codes?

32 # 3 - Waste Determinations Failure to determine if any of your solid wastes are Hazardous Wastes Testing Characteristics Arizona Licensed Laboratory By Knowledge Material Safety Data Sheets Disposal Service Waste Materials Profile Sheet Product Label and Manufacture s Info.

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34 HAZARDOUS WASTE DETERMINATION AND GENERATOR STATUS Facility: Date: WASTE PRODUCIN G PROCESS DESCRIPTI ON WASTE STREAMS/WASTE TYPES FOR EACH PROCESS NAME AND EPA WASTE NUMBER WASTE DETERMINAT ION METHOD WASTE HANDLING UNIT DESCRIPTION CONTAINER/TANK/P ILE/SPILL/ETC STORAGE/TREATME NT/DISPOSAL UNIT STATIC OR MAXIMU M CAPACI TY MONTHLY GENERATIO N AND/OR PROCESS RATE AMOU NT ON- SITE PROCESS DESTINATION DESCRIPTION ON-SITE/OFF- SITE TSD/RECYCLED /ETC

35 Check Out Your Waste Service Companies..

36 #2 Keep Containers Closed Failure to keep containers of hazardous waste closed except when adding or removing waste.

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42 #1 Marking Requirements Failure to mark containers with: The Words HAZARDOUS WASTE The accumulation start date; when waste is first placed in the container

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45 Maintaining Compliance Things To Do Inspect Your Facility Inventory Your Materials, Structures, & their State of Repair Respond to Problems Use an Inspection Checklist/Schedule Create an Environmental Calendar for due dates and records Initiate Pollution Prevention Establish an Environmental Management System

46 Ask Questions; Ask for Help Participate in Professional Associations EPA Web Site for Hazardous Waste EPA Hazardous Waste (RCRA) Orientation Manual EPA Hazardous Waste Program for Small Businesses Compliance Assistance Clearinghouse for Tribes, Industry & Government Pollution Prevention Resource Exchange NFPA National Fire Protection Association

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49 Why Monitor Air Quality? QUESTIONS? 49

50 Contact Information: Waste Program Gila River Indian Community Department of Environmental Quality P.O. Box 97/35 Pima Street Sacaton, Arizona (520)