Do you know how to comply with federal hazardous waste regulations? Do you know what is considered hazardous waste?
Wastes are considered hazardous if they appear on one of four lists published in the Code of Federal Regulations. There are currently more than 500 wastes listed because they are known to be harmful to human health and the environment.
A material may be hazardous even if it doesn’t appear on the lists if it: Is an ignitable waste (paints, degreasers and solvents) Is a corrosive waste (rust removers, acid cleaning fluids and battery acid) Is reactive waste, meaning it is unstable and explodes or produces toxic fumes, gases and vapors when mixed with water or placed under heat or pressure (cyanides or sulfide-bearing wastes Is a toxic waste, meaning it is harmful or fatal when ingested or absorbed or leaches toxic chemicals into the soil or ground when land filled (cadmium, lead or mercury)
Typical Wastes Generated Type of BusinessHow GeneratedTypical Wastes Construction Paint prep and painting, floor work, heavy construction and construction vehicles Ignitable wastes, paint wastes, acids/bases Laboratories Diagnostic and other lab testingSpent solvents, unused reagents, reaction products, testing samples, contaminated materials Vehicle Maintenance Degreasing, rust removal, paint prep, tank cleanout, installation of lead-acid batteries Acids/bases, solvents, ignitable wastes, paint wastes Equipment Repair Degreasing, cleaning, paintingAcids/bases, toxic wastes, ignitable wastes, paint wastes, solvents
PCB’S (Polychlorinated Biphenyls) Hazardous Waste ? PCBs are not hazardous waste under federal regulations, although many of the management requirements are similar to those for hazardous wastes. Some states, however, choose to include PCBs in their Resource Conservation and Recovery Act (RCRA) hazardous waste programs. Therefore, management and disposal of PCBs in these states are subject to requirements of both TSCA (Toxic Substances Control Act of 1976) and RCRA.
PCB’s What are they? PCBs are a family of over 200 organic compounds. They vary from mobile, oily liquids to white solids, or resins. PCBs demonstrate a high degree of chemical stability, high boiling points, low flammability, and low electrical conductivity. These properties made PCBs attractive for many high-temperature and electrical insulating applications. However, these same properties cause PCBs to remain in the environment for a long time. PCBs accumulate throughout the food chain, and EPA considers them carcinogens.
What are Polychlorinated Biphenyls Synthetic Organic Chemicals Carcinogens Teratogens colorlessNo taste nor smell, colorless to light yellow
What are PCB used for? Coolants Lubricants Transformers Capacitors Insulators
Where are they currently? Mostly in light ballastsMostly in light ballasts TransformersTransformers Old appliancesOld appliances An IDEA on how to manage PCB’s Identify all potential PCB’sIdentify all potential PCB’s Develop a plan to manage PCB’sDevelop a plan to manage PCB’s Eliminate leaky PCB materialEliminate leaky PCB material Asses environmental impactAsses environmental impact
PCB Classifications Regulation of PCBs and PCB-containing materials derives from the concentration of PCBs in a material. Below 50 parts per million PCBs, the material is “non-PCB.” Between 50 and 500 parts per million PCBs, the material is “PCB-contaminated.” Above 500 parts per million PCBs, the material is a PCB.
Manage PCBs Inspect every 3 months Keep logs of inspections When removed from service, make record & keep with inspection log
Eliminate Damaged PCB Material Keep PCB containing material in a approved container Dispose of within 1 year
Access the Damage Spill plan in place Emergency plan in place Disposal equipment & plan in place Records kept and available Personnel trained on what to do
Plan for PCBs Check transformers for leaks every 3 months.Check transformers for leaks every 3 months. Storage container checked for leaks every 30 days.Storage container checked for leaks every 30 days. If storing over 99.4 lbs., must have a annual document log and records of disposal of PCBs and PCB itemsIf storing over 99.4 lbs., must have a annual document log and records of disposal of PCBs and PCB items
Item-by-Item Instructions for Completing EPA Form 7720-12 Return completed form to: Fibers & Organics Branch (7404T) Office of Pollution Prevention & Toxics U.S. Environmental Protection Agency 1200 Pennsylvania Ave., N.W. Washington, DC 20460-0001 FAX – 202-566-0473 PCB Transformer means any transformer that contains 500 ppm or greater PCB dielectric. For PCB concentration assumptions applicable to transformers containing three pounds or more of fluid other than mineral oil, see 40 CFR 761.2. For provisions permitting reclassification of electrical equipment containing 500 ppm or greater PCBs to PCB- Contaminated Electrical Equipment, see 40 CFR 761.30(a) and (h). Type or print in black ink all items, except Item 3, “Certification.” If you must use additional sheets, indicate clearly the number of the item on the form to which the information on the separate sheet applies. Item 1 Company Name: Enter the name of the company which owns the equipment. Address: Enter the street, city, state, and zip code of the company. Contact Name and Phone Number: Enter the name and business telephone number of the person who should be contacted regarding information submitted on this form.
Item 2a Location of PCB Transformers: Enter the address (street, city, state, and zip code) where the PCB Transformer(s) is located. Please note that the address you give must be a physical address, not a P.O. Box. Route numbers are acceptable provided they include enough specificity to assist emergency response personnel in determining the location of the transformer(s). Item 2b Number (No.) of Transformers and weight (wt..): Enter the total number of PCB (500 ppm or greater) Transformers at this location (address) and the total weight (wt..) in kilograms (kg) of the PCB dielectric fluid in the transformer(s). Item 2c Any transformers containing flammable dielectric fluid: (Response optional) Circle yes or no if you have any knowledge that there are or are not transformers at this location (address) that contain flammable (see 40 CFR 261.21(a)(1) - Characteristics of Ignitability) dielectric fluid. ***Please note this form has been designed to accommodate companies submitting registrations for multiple locations. However, companies with more than 4 locations may choose to submit an additional form(s) or an attachment(s). Item VII -- Certification: This certification must be signed by the owner, operator, or an authorized representative of the transformer owner or operator of the facility or property where the unit is located. An “authorized representative” is a person responsible for the overall operation of the facility (i.e., a plant manager or superintendent, or a person of equal responsibil ity). All notifications must include this certification to be complete. EPA Form
TO REGISTER YOUR TRANSFORMERS THAT CONTAIN PCB’S GREATER THAN 500 PPM GO TO EPA WEB SITE AND REQUEST FORM 7720-12
Spill Plan for PCBs Phones numbers to NRC & EPA Phone number to an authorized disposal contractor Keep a PCB disposal container on site Laboratories in the area that test for PCBs National Response CenterNational Response Center 1-800-424-8802 EPAEPA if over 10 lbs.
PCB’s Check you state regulations to see if PCB’s fall under RCRA as well as TSCA. REMEMBER DON’T ASSUME, IT WILL GET YOU IN TROUBLE EVERY TIME.
The EPA has defined three categories of hazardous waste generators: 1. Conditionally exempt 2. Small quantity generators 3. Large quantity generators
Conditionally exempt small quantity generators generate less than 220 pounds of hazardous waste per month
Reminder: MOST OF OUR FACILITIES ARE CONDITIONALLY EXEMPT SMALL QUANTITY GENERATORS AND SHOULD LOOK CLOSELY AT THE REGULATIONS THAT PERTAIN TO THAT STATUS
Small quantity generators generate between 220 pounds and 2,200 pounds of hazardous waste per month.
Large quantity generators generate more than 2,200 pounds of hazardous waste per month.
Requirements for Conditionally Exempt Small Quantity Generators Identify all hazardous material that you generate You may not store more than 2,200 pounds of hazardous waste on site at any given time. Ensure that delivery of hazardous waste is:
ØTo an off-site treatment or disposal facility that is state or federally regulated for treatment, storage or disposal ØTo a facility permitted, licensed or registered by a state to manage municipal or industrial solid waste ØTo a facility that uses, reuses, or legitimately recycles the waste ØTo a universal waste handler or destination facility subject to the requirements of 40 CFR Part 273
REVIEW Identify your hazardous waste Including proper storage and labeling Comply with storage quantity limits Ensure proper treatment and disposal of your waste
Requirements for Small Quantity Generators If you generate between 220 and 2,200 pounds of hazardous waste per month, you are a Small Quantity Generator. To be compliant with requirements, you must:
Obtain and use an EPA Identification Number. Obtain a copy of EPA Form 8700-12, Notification of Hazardous Waste Activity Fill in the form completely. Be sure to sign the certification at Item “14”. Note that state forms may contain additional sheets Send completed forms to your state hazardous waste contact listed in the information booklet (You will receive this along with the form.)
MANAGING HAZARDOUS WASTE ON SITE Small Quantity Generators can accumulate no more than 13,228 pounds of hazardous waste on site without a permit. You can accumulate this amount of waste for up to 180 days (270 days if you must transport it more than 200 miles for disposal, treatment or recovery.
Small Quantity Generators must accumulate wastes in tanks or containers, like 55 gallon drums. All containers must: Be labeled “HAZARDOUS WASTE” and include the date that waste was initially generated Be made of a material that is compatible with the hazardous waste being stored. This prevents corrosion or reactivity Be kept closed during storage, except when adding or removing waste Be kept in good condition. Inspect storage areas regularly to look for leaks and deterioration
And probably the most important rule to follow with Hazardous Waste storage is: DO NOT MIX WASTE MATERIALS. IT CAN CREATE AN UNSAFE WORK ENVIRONMENT AND LEAD TO MORE COMPLEX AND EXPENSIVE CLEAN-UPS.
The Better Way…Waste Minimization Do not mix wastes to create new wastes Change materials, processes or both Recycle and reuse manufacturing materials Safely store hazardous products (prevent spills/leaks) Make a real effort to minimize waste generation
Shipping Waste Off-Site Small Quantity Generators may send their waste only to a regulated Treatment, Storage and Disposal Facility (TSDF). Check with your state authorities to be sure your facility has all necessary permits.
Package, label and mark your shipment Prepare a hazardous waste manifest to accompany your shipment Maintain copies of all manifests for life Include a notice and certification with the first waste shipment Ensure the proper management of any hazardous waste shipments you make
When selecting a hazardous waste transporter or TSDF/Recycler… Talk to colleagues and/or competitors to see who they are using Talk to reps at trade shows Check with the Better Business Bureau Ask your state agencies if transporters / recyclers have an EPA number
When you are sending out wastes, make sure that you always get a copy of the shipping manifest. You are responsible for the materials even when they leave your property. Fill out the manifest completely and accurately.
LARGE QUANTITY GENERATORS If you generate more than 2,200 pounds of hazardous waste monthly, you are subject to the full set of hazardous waste regulations.
These include, but are not limited to: Determining amounts of waste generated Applying for an EPA Identification Number Preparing waste for shipment and filling out manifests Accumulating waste no more than 90 days, without a permit Preparing a biennial report If applicable, monitor air emissions