Presentation on theme: "Smithfield 2012 Environmental Conference"— Presentation transcript:
1Smithfield 2012 Environmental Conference Hazardous WasteBy Susan Murphy, FFI
2Hazardous Waste Most facilities are SQG or CESQG CESQG means less than 220 lbs hazardous waste generated in ANY calendar monthHazardous wastes are either Listed (P- U- D-toxic lists ), listed process (F-list for nonspecific sources), or characteristic (D001,Doo2,Doo3)
3Hazardous Waste a word about inspections… Any unmarked container is a potential hazardous waste violationWhy does the RCRA inspector look at our Universal Waste collection locations?It is OK to dump the expired cleaning chemical down the drain—OR IS IT?
4Hazardous Waste Waste Determinations are key Every employee should feel confident that what they are doing is “legal”Wastes, at the point of generation, need to be characterizedThe facility needs a process to make hazardous waste determinations
5Hazardous Waste ask the EC The lab botches a titration and the endpoint pH is 13. Can this go down the drain?Food safety calls and a damaged bag of sodium nitrite needs to be gotten rid of. What can they do with it?We have metal cans that held epoxy paint. Can these go in the trash dumpster?You find a broken fluorescent light bulb. What should you do with it?Safety Kleen picks up and recycles parts washer solvent. So this is not a hazardous waste, right?
6DEFINITION OF A SOLID WASTE All materials FIGURE 1DEFINITION OF A SOLID WASTEAll materialsSolid, liquid, semi-solid or contained gaseous material which is:DiscardedServed its intended purposeA manufacturing byproductOTHERGARBAGE, REFUSE OR SLUDGEDoes 261.4(a) exclude your material from RCRA because it is one of the following:1.domestic sewage 2.CWA point source discharge 3. irrigation return flow 4. AEC source, special nuclear or byproduct material 5. in situ mining wasteTHE MATERIAL IS NOT A RCRA SOLID WASTEYESTHE MATERIAL IS A RCRA SOLID WASTE IRRESPECTIVE OF WHETHER YOU DISCARD IT, USE IT, REUSE IT, RECYCLE IT RECLAIM IT, STORE IT, OR ACCUMULATE IT FOR PURPOSES OF ABOVENO
7DEFINITION OF A HAZARDOUS WASTE FIGURE 2DEFINITION OF A HAZARDOUS WASTEIs the solid waste excluded from regulation under 261.4(b)?YESIs the solid waste listed in Part 261, Subpart D, or is it a mixture that contains a waste listed in Subpart D?NOHas the waste or mixture been excluded from the lists in Subpart D or in accordance with and ?YESDoes the waste exhibit any of the characteristics specified in Part 261, Subpart C?NONOYESTHE WASTE IS SUBJECT TO CONTRTOL UNDER SUBTITLE D (IF LAND DISPOSED)THE WASTE IS A HAZARDOUS WASTE. SEE FIGURE 3
8SPECIAL PROVISIONS FOR CERTAIN HAZARDOUS WASTE FIGURE 3SPECIAL PROVISIONS FOR CERTAIN HAZARDOUS WASTETHE WASTE IS A HAZARDOUS WASTEIs it generated by a small quantity generator as defined in 261.5?YESIt is subject to the special requirements of 261.5Therefore, it must be intended to be discarded. IT IS SUBJECT TO THE SUBTITLE C REGULATIONS IN FIGURE 4.Is it or is it intended to be legitimately and beneficially used, reused, recycled, or reclaimed?NOIs it a sludge or is it listed in Part 261 Subpart D or is it a mixture containing a waste listed in Part 261, Subpart D?NOIT IS NOT SUBJECT TO REGULATION UNDER SUBTITLE C.IT IS SUBJECT TO THE FOLLOWING WITH RESPECT TO ITS TRANSPORTATION OR STORAGE:Notification under Section 3010Parts 262 and 263Part 264, Subparts A through EPart 265, Subparts A through E, and G, H, I, J, and LParts 270 and 124
9REGULATIONS FOR HAZARDOUS WASTE NOT COVERED IN DIAGRAM 3 FIGURE 4REGULATIONS FOR HAZARDOUS WASTE NOT COVERED IN DIAGRAM 3All persons who handle hazardous waste subject to control under Subtitle C not covered in Figure 3Notify EPA according to Section 3010 of RCRA and obtain EPA ID no.GENERATORSTRANSPORTERSOWNERS OR OPERATORS OF T/S/D FACILITIESOn-site generators storing wastes for < 90 days for subsequent shipment off siteAll other Owners or OperatorsPartPart 262Part 262Those qualifying for Interim StatusThose who do not qualifyPart 265
10Hazardous Waste?? Is it OK to save up my hazardous waste until the container is full to save money??? We are cleaning out an area and I found over 1,000 kg of wastes. Do I have to become a LQG??? The vendor preprints my manifests. They are responsible for the paperwork accuracy because I am paying them, right?A lab test uses a hazardous chemical in a large volume of sample. Can I decant the waste to reduce the volume before giving it to the vendor?
11Polychlorinated Biphenyls (PCBs) 40 CFR Part 761 Transformers—Request the placement of a Non-PCB label even if it is owned by power company.Don’t forget to “look up” on power polesDo you have a SOP for plant maintenance and electricians?Where and how to store ballasts until the part number is verified as not containing PCBsMost landfills take PCB ballasts if they are not leaking.
13Notification of Regulated Waste Activity EPA updated the Form and Instructions in This requirement is found in the notification requirements of RCRA Section 3010.All generators of hazardous waste are to submit a Notification of Regulated Waste Activity Form. IF YOU, AT ALL TIMES, FOLLOW ALL CESQG REQUIREMENTS OF 40 CFR 261.5, THEN YOU DO NOT HAVE TO FILE THIS FORM.If your status temporarily changes (i.e., from CESQG to SQG), file a form. Submit another one right away to change your status back!It is simple, easy, and F U N!!
14Notification FormSection 3010 of Subtitle C of Resource Conservation and Recovery Act (RCRA) requires any person who generates,transports, or recycles regulated wastes or who owns or operates a facility for the treatment, storage, or disposal ofregulated wastes to notify EPA of their activities, including the location and general description of the activities andthe regulated wastes handled. Respondents must submit the information required in the Notification of Subtitle CActivity Instructions and Form booklet by completing the RCRA Subtitle C Site Identification Form [EPA Form]. This is mandatory reporting by the respondents.