Hazardous Waste Management - Arkansas …...Hazardous Waste Generators Presented at AEF’s April...
Transcript of Hazardous Waste Management - Arkansas …...Hazardous Waste Generators Presented at AEF’s April...
Annual Training for
Hazardous Waste
GeneratorsPresented at AEF’s April 2018 Regulated Waste Seminar
By: Garrett Mikel
13000 Cantrell Rd.
Little Rock, AR 72223
(501) 975-8100
www.ecci.com
• Arkansas Pollution Control & Ecology
Commission Regulation No. 23
“Hazardous Waste Management”
regulates active facilities
• Generators;
• Transporters; &
• Owners & Operators of Treatment, Storage, &
Disposal facilities.
• Section 262.34 references Section 265 (Interim TSDFs)
• All persons who are handling, transporting, or storing hazardous
wastes must be trained within 6 months of their hire date.
– Prior to training, accompanied by trained personnel.
– Annual Refresher Courses
• Instruction in hazardous waste management procedures relevant to
the positions in which they are employed.
– Contingency Plan!
• Records
– Job Title, Description, and Type, Amount, and Frequency of Training
– Retain on current personnel until closure of facility or 3 years from end
of employment.
Annual Training Requirements
• Solid Waste (includes solids, liquids, & gases)
– When it is discarded or abandoned
– When it has no value
– Not necessarily Hazardous
• All Hazardous Waste is Solid Waste
but not all Solid Waste is Hazardous Waste
When is it a “Waste”
• Process Knowledge
• Testing
• Characteristic or Listed?
When is a Solid Waste
Hazardous?
Hazardous Waste
Determination• Characteristic Hazardous Waste
– Ignitable (D001)
– Corrosive (D002)
– Reactive (D003)
– Toxic (D004-D043)
• Based on specified tests or knowledge
– Process knowledge or records of analysis
• CAREFUL!- Must be correct & convincing
• Recommend keeping on-record for 3 years
Hazardous Waste
Determination• Listed Hazardous Waste
– Non-Specific Sources (F)
• Chemicals
– e.g. F002- Spent Tetrachloroethylene (>10% before use)
– Specific Sources (K)
• Industry/Manufacturing Processes
– e.g. K045- Spent carbon from the treatment of
wastewater containing explosives
– Products that become wastes (P or U)
• Off-spec, residues, or contaminated materials
– e.g. U210- Tetrachloroethylene (Sole Active Ingredient)
• Federal Regulations
– 40 CFR 261 Subpart D Tables
• State Regulations
– APC&E Commission Regulation 23
• Incorporates Federal Tables
• Waste Analysis/Characterization Services
• Third Party Waste Management or
Disposal Services
– Generator assumes liability.
Hazardous Waste
Determination Help
• Generating, storing, marketing, burning,
transporting, or disposing of a hazardous
waste
– Complete Form 8700-12: Notification of
RCRA Subtitle C Waste Activity
• Arkansas version available on ADEQ website
• Update form when facility has changes in contact
information, ownership, or waste codes
Notification of Regulated
Hazardous Waste Activity
Generator Status
• Conditionally Exempt Small Quantity
Generators (CESQGs/VSQGs)
– Generate <220 pounds/month
• <2.2 pounds/month Acutely Hazardous (P wastes)
– Accumulate <2,200 pounds
• <2.2 pounds Acutely Hazardous
Generator Status
• Small Quantity Generators (SQGs)
– Generate >220 & <2,200 pounds/month
• <2.2 pounds/month Acutely Hazardous (P wastes)
– Accumulate <13,200 pounds
• <2.2 pounds Acutely Hazardous (P wastes)
• Accumulation time limited to <180 days
– EPA ID Number, Emergency Procedures,
Recordkeeping, & Reporting Required
Generator Status
• Large Quantity Generators (LQGs)
– Generate >2,200 pounds/month
• >2.2 pounds/month Acutely Hazardous (P wastes)
– No Accumulation Weight Limits
• Accumulation time limited to <90 days
– EPA ID Number, Emergency Procedures +
Contingency Plan, Recordkeeping, &
Reporting Required
Accumulation & Storage of
Hazardous Waste• Storage Units
– Containers
– Hazardous Waste Tanks
– Drip Pads
– Containment Buildings
• Satellite & Central Accumulation Areas
Satellite Accumulation Areas
• Container at or near the point of generation– Under the control of the operator
– Containers ≤55 gallons
(≤1 quart Acutely Hazardous)
– Portable & DOT Approved
• Marked “HAZARDOUS WASTE” or other identifying label– All Containers
– No Date (no time limit)
Satellite Accumulation Areas
• Containers in Good Condition– No leaks or deterioration
– Compatible with materials being stored
• Closed Containers– No Spills
• Full containers (55 gallon) must be moved to Central Accumulation Area within 3 days.– Dated (after full or finished using)
– Moved by employee “thoroughly familiar with proper waste handling procedures”
Central Accumulation Areas
• Emptying Containers
– No more than 1 inch of remaining waste
• SQG – 180 days
– Incompatible Wastes
• LQG – 90 days
– Incompatible Wastes
– Ignitable & Reactive Wastes
• Kept away from ignition or reaction sources
• NO SMOKING signs nearby
Central Accumulation Areas
• Weekly Inspections– Leaks, Corrosion, Closed Lids
– Labels, Dates, Containment, Emergencies, Signage, Aisle Space
– Qualified Inspector with Documented Training
Hazardous Waste Labels
Universal Wastes
• Alternative standards for
– Batteries, Pesticides, Mercury-Containing
Equipment, Bulbs &, Consumer Electronics
• Universal Waste Handler Status
– Small Quantity Handlers of Universal Waste
(SQHUW)
• <11,000 pounds on-site
– Large Quantity Handlers of Universal Waste
(LQHUW)
• ≥11,000 pounds on-site
Universal Wastes
• Accumulation time limited to ≤1 year
• EPA ID Number Required for LQHUW
• Employee Training for Handling &
Emergency Procedures
• No Hazardous Waste Manifest Required
• Labeling
– “Universal Waste – Batteries, or Waste
Batteries, or Used Batteries”
• Same for other Universal Waste
Universal Waste Labels
Waste Oil vs. Used Oil
• Waste Oil- Generic Term
– New but may or may not be contaminated by
hazardous substances
– Unusable / No Value
– Not Defined in Hazardous Waste Regulation
• Used Oil- Precise Regulatory Term
– Used and may be contaminated by physical
or chemical impurities
– May be refined and recycled / Valuable
Good Housekeeping
Bad Housekeeping
Safety Procedures
All employees should be aware of the locations of:
• Emergency Plan/Procedures
• Emergency Telephones & Telephone Numbers
• Emergency Evacuation Routes & Exits
• Fire Alarm Pull Stations
• Fire Extinguishers
• Spill Response Kits & Materials
• First Aid Kits
• Chemical Alarms
Contingency Plan
• Each owner or operator must have a
contingency plan to minimize hazards. – Describes actions personnel take in response to fires,
explosions, or any unplanned sudden or non-sudden release of
hazardous wastes.
• Emergency contacts must be listed on the plan.
• Emergency equipment should be listed on the
plan.
• The plan is initially submitted to all local
responders. – Changes to the plan must be resubmitted to each responder.
Transportation & Disposal
• Transport by a permitted Hazardous
Waste transporter
• Hazardous Waste Manifest
• Shipped to a permitted Treatment,
Storage, and Disposal Facility (TSDF)
• DOT Regulations and Restrictions
Return Manifests
• LQG
– Contact Transporter/Disposal Facility
• Within 35 Days
– Report
• Within 45 Days
• SQG
– Report
• Within 60 Days
Annual Hazardous Waste
Report• Due March 1 of every year to ADEQ
• Online using specific ADEQ reporting
forms
• Report describes:
– General facility information
– Amount & type of hazardous waste, universal
waste, & used oil generated during the
previous calendar year by waste stream.
– Shipment information (who shipped it & who
received it)
Summary
• All containers MUST be in good condition – No leaks, bulging,
rusting, damaged, or dented drums.
• All containers MUST be sealed (lids or bungs on) at all times that
waste is not being added or removed.
• If any containers leak - place waste in new or good used empty
drum or overpack.
• DO NOT mix different waste types or use drums that held another
type of material.
Summary
• When emptying any containers, they can have no more than 1 inch
of remaining waste to be considered empty.
• Make sure that all containers are labeled with “Hazardous Waste”
label & that the label is complete – accumulation date, facility name,
waste material, description (waste codes) & other information.
• Satellite Accumulation point is at or near generation point.
• Waste containers CANNOT be stored for more time than allowed by Generator Status.
• Make sure that drums have enough space between them to see the labels & inspect. (3 feet between rows & stacked 2 high max).
Summary
• Inspect containers weekly & DOCUMENT!!!
• Hazardous waste cannot be moved from the satellite area with out being properly labeled.
• Hazardous waste can only be delivered to the hazardous waste storage area by trained employees.
• Hazardous waste must be shipped off-site with a completed Hazardous Waste Manifest.
• Know where the all emergency numbers, fire alarms, fire extinguishers & spill equipment are located.
Your Mission…
• Annual Employee Training Requirements
• Specific Presentations• LQG• SQG
• Contingency Plan!
• Records