2CFR 40 EPA has implemented: Regulations for Identification of wastes Performance standards for generatorsHazardous waste facility permit programMandated annual training for employees who handle, process or may regularly be exposed to hazardous waste
3Training Objectives Understand types of waste generators Define hazardous wastesDescribe proper handling and storage of hazardous wasteSelect proper waste containersLabel and mark waste containersDiscuss truck loading requirementsComplete paperwork for waste shipmentResponse to emergencies
4Types of GeneratorsLarge quantity –generates >1000kg(2205 lbs) in any monthSmall quantity - generates <1000kg(2205 lbs) in any calendar month (approx 5 drums)Never accumulates >6000kg on site* Very small quantity – generates < 100kg per month; never >1000kg on site
5SQG Must Obtain a USEPA identification number Identify Hazardous wastesKeep records of wastesInspect waste containers regularly for damage; document these inspectionsDispose of waste through licensed waste haulers/facilitiesFill-out and retain proper shipping papers
6What is a hazardous waste? A solid waste, or combination of solid wastes, which because of its quantity, concentration, or physical, chemical, or infectious characteristics may:Cause or significantly contribute to an increase in mortality or an increase in serious irreversible, or incapacitating reversible illness; orPose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, disposed of, or otherwise managed.
7What is a hazardous waste? Contd Listed Wastes – automatically hazardous if it is named on RCRA list (>400 chemicals)Characteristic Waste- waste isIgnitable – easily combustible/flammableCorrosive - pH 2.0 or less;12.5 or moreReactive – unstable or reacts violently with water or other materialsToxic – if extract has heavy metals, pesticides
8What is a Hazardous Waste? contd Acutely Hazardous wastes- these are so hazardous (primarily some pesticides or dioxin-containing wastes) that generation of 2.2 lbs or having that much on-site would be enough to categorize a company as a Large quantity generator
9RBP waste RBP is a small quantity generator Primary hazardous waste is solvent from tank washout. This is collected at a site other than the storage site. Suitable container for flammable liquid is a steel drum.Satellite – waste drum collection in Chem Mix#1 area; maximum 55 galsStorage- Flammable Storage Room
10Ignitable Wastes Code D001 if: A liquid with flash point <140F; exception is an aqueous solution with <24% alcoholA non-liquid capable at 77F and 760mm pressure of causing fire due to friction, absorption of water or spontaneous reaction and, if ignited, burns vigorously
11Ignitable Wastes continued It is an oxidizer, such as chlorate, permanganate, inorganic peroxide, or a nitrate that yields oxygen to stimulate combustion of organic material
12RBP WasteCorrosive wastes – unusable raw materials and/or rejected/obsolete products that cannot be utilized. Suitable containers are those not damaged by corrosive nature of waste.Storage- return areaA waste is not a waste until RBP makes the determination that we cannot use it.
13Corrosive Wastes NR EPA waste code D002 Classed as corrosive waste if: Aqueous solution wiyh pH<2 or >12.5, orLiquid that corrodes plain carbon steel with carbon content of 0.20% at rate >6.35mm/0.25” year at 55C.
14Reactive Waste If ( Code D003 ) Reacts violently with water, or Forms potentially explosive mixtures with water, orNormally unstable and readily undergoes violent change without detonating, orWhen mixed with water generates toxic gases sufficient to be danger to humans
15Reactive Waste continued If a cyanide which when exposed to pH between can generate toxic gases.example would be the cyanide locked in cabinet in Brad’s area. If we decided we couldn’t use it or find a user this would be disposed of under this hazardous waste code
16Toxic Wastes EPA waste codes D004-D043 Specific test method used to determine level of listed hazardous material. Examples are mercury, chromium, lead, pesticides, benzene
17Waste Treatment RBP has no permit as a waste treatment facility Elementary neutralization of a waste whose only hazard is pH based is allowed as long as:it was generated on-site, andis in a suitable container
18Hazardous Waste Identification Satellite collectionMaximum of 55 gallonsMarked as Hazardous Waste and appropriate hazard warning – flammable, etc.Keep closed at all times when not actively adding waste to container. A funnel with a lid is okay as long as lid kept closed.
20Hazardous Waste Identification Once container is full, the date is entered on the label as the Accumulation Start DateContainer must be removed to the storage area within 48 hoursRBP, as a SQG, has 180 days to dispose of the waste.The stored waste must be inspected regularly for damage. Hazardous Waste Drum Inspection Log filled out weekly. Form # 13-7.
21Waste Transport Transport only by licensed Hazardous Waste Hauler Shipment not accepted without a manifest signed by the generator (RBP)Transporter must sign and date manifest acknowledging acceptance of the waste and give us a copy of the signed document prior to leaving.Manifest must accompany shipment.Receiving TSD must return signed copy of manifest to RBP within 30 days acknowledging receipt of waste. Not needed if transporter is also the TSD.
22Manifest System Uniform Hazardous Waste Manifest info Generator name and addressGenerator USEPA ID numberManifest Document numberTransporter nameTSD name and address
23Manifest info continued US DOT description of wastes including Hazardous Waste ID numbersNumber of containers, total quantityEmergency contactsSpecial handling, PPE, etc.Signed by RBP representative + titleSigned by Truck DriverDatePlant Manager is responsible unless signer can read, write and understand English and has personal knowledge of the accuracy of the manifest.
29Waste MinimizationRBP signature on Manifest automatically commits us to having a waste minimization programMinimize waste by:Using out-of-spec product in blend-off programFinding alternate users of off-spec/obsolete product or raw materials
30Alternate Users must Use 100% of what he takes from us Provide a written agreement signed by a representative of that companyUse the manifest system to receive itExample is use of our solvent waste for fuel value in kilns
31Emergency response to a spill Follow our Safety plan proceduresSave the peopleSave the EnvironmentSave the moneyThe first thing to do is recognize the hazard, alert supervisor, contain the spill if safe to do so.Use PA system to alert employees of danger and/or need for any evacuation.If spill can’t be handled internally, notify authorized respondents ( AAA Environmental Industries, WA Fire department, etc.) See Contingency Plan.
32Handling Spills Containment procedures including use of proper PPE Use and recovery of sorbent materials-use minimum neededNeutralize acid and alkaline spillsMinimize dilution of solvent spillsProper handling and containerization of hazardous wastes.