1. Annual RCRA Hazardous Waste Training Program

2. CFR 40 EPA has implemented: Regulations for Identification of wastes
Performance standards for generators
Hazardous waste facility permit program
Mandated annual training for employees who handle, process or may regularly be exposed to hazardous waste

3. Training Objectives Understand types of waste generators
Define hazardous wastes
Describe proper handling and storage of hazardous waste
Select proper waste containers
Label and mark waste containers
Discuss truck loading requirements
Complete paperwork for waste shipment
Response to emergencies

4. Types of Generators
Large quantity –generates >1000kg(2205 lbs) in any month
Small 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

5. SQG Must Obtain a USEPA identification number
Identify Hazardous wastes
Keep records of wastes
Inspect waste containers regularly for damage; document these inspections
Dispose of waste through licensed waste haulers/facilities
Fill-out and retain proper shipping papers

6. What 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; or
Pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, disposed of, or otherwise managed.

7. What is a hazardous waste? Contd
Listed Wastes – automatically hazardous if it is named on RCRA list (>400 chemicals)
Characteristic Waste- waste is
Ignitable – easily combustible/flammable
Corrosive - pH 2.0 or less;12.5 or more
Reactive – unstable or reacts violently with water or other materials
Toxic – if extract has heavy metals, pesticides

8. What 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

9. RBP 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 gals
Storage- Flammable Storage Room

10. Ignitable Wastes Code D001 if:
A liquid with flash point <140F; exception is an aqueous solution with <24% alcohol
A 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

11. Ignitable Wastes continued
It is an oxidizer, such as chlorate, permanganate, inorganic peroxide, or a nitrate that yields oxygen to stimulate combustion of organic material

12. RBP Waste
Corrosive 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 area
A waste is not a waste until RBP makes the determination that we cannot use it.

13. Corrosive Wastes NR EPA waste code D002 Classed as corrosive waste if:
Aqueous solution wiyh pH<2 or >12.5, or
Liquid that corrodes plain carbon steel with carbon content of 0.20% at rate >6.35mm/0.25” year at 55C.

14. Reactive Waste If ( Code D003 ) Reacts violently with water, or
Forms potentially explosive mixtures with water, or
Normally unstable and readily undergoes violent change without detonating, or
When mixed with water generates toxic gases sufficient to be danger to humans

15. Reactive 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

16. Toxic Wastes EPA waste codes D004-D043
Specific test method used to determine level of listed hazardous material. Examples are mercury, chromium, lead, pesticides, benzene

17. Waste 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, and
is in a suitable container

18. Hazardous Waste Identification
Satellite collection
Maximum of 55 gallons
Marked 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.

19. Solvent Waste Collection

20. Hazardous Waste Identification
Once container is full, the date is entered on the label as the Accumulation Start Date
Container must be removed to the storage area within 48 hours
RBP, 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.

21. Waste 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.

22. Manifest System Uniform Hazardous Waste Manifest info
Generator name and address
Generator USEPA ID number
Manifest Document number
Transporter name
TSD name and address

23. Manifest info continued
US DOT description of wastes including Hazardous Waste ID numbers
Number of containers, total quantity
Emergency contacts
Special handling, PPE, etc.
Signed by RBP representative + title
Signed by Truck Driver
Date
Plant Manager is responsible unless signer can read, write and understand English and has personal knowledge of the accuracy of the manifest.

26. EPA Hazardous Waste ID Numbers
40CFR261 Identification and listing of hazardous waste
D001 is code for our ignitable solvent waste

27. Universal Waste Computer CRTs
Fluorescent light bulbs – if broken becomes a hazardous waste.
Thermostats
Pesticides
Batteries
A SQG not required to notify EPA of handling activities

28. Universal Wastes Label as Universal Waste –Lamp(s)
Universal Waste – Pesticide(s)
Etc.

29. Waste Minimization
RBP signature on Manifest automatically commits us to having a waste minimization program
Minimize waste by:
Using out-of-spec product in blend-off program
Finding alternate users of off-spec/obsolete product or raw materials

30. Alternate Users must Use 100% of what he takes from us
Provide a written agreement signed by a representative of that company
Use the manifest system to receive it
Example is use of our solvent waste for fuel value in kilns

31. Emergency response to a spill
Follow our Safety plan procedures
Save the people
Save the Environment
Save the money
The 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.

32. Handling Spills Containment procedures including use of proper PPE
Use and recovery of sorbent materials-use minimum needed
Neutralize acid and alkaline spills
Minimize dilution of solvent spills
Proper handling and containerization of hazardous wastes.

33. Spill Kits at Chem#1 Entrance

34. Spill Kit Pillows- Shipping Dept