Understanding universal & hazardous waste

Understanding Universal & Hazardous Waste

Objectives – Hazardous Waste Management
Definition of Solid Waste
Definition of Hazardous Waste
Characteristic
Listed
Generator Status and Requirements
Waste Manifests
Special Solid Waste Procedures

Solid Waste Definition
Not based on physical form of the material (i.e., solid, liquid, or contained gas)
Defined as any material that is
Discarded by being abandoned (disposed of, burned, or incinerated)
Inherently waste-like (e.g., dioxin wastes)
Military munitions
Recycled (reuse or reclamation)

Hazardous Waste
Waste with properties that make it dangerous or capable of having a harmful effect on human health or the environment
Generated from many types of sources
EPA developed identification system using four questions to determine if waste is hazardous

Hazardous Waste
Hazardous waste is a subset of solid waste, defined at 40 CFR 261.3
Treatment, Storage and Disposal of hazardous waste is covered by Subtitle C of RCRA
A material must first meet the definition of a solid waste in order to be considered a hazardous waste
Categories of hazardous waste include:
Characteristic Waste (D-listed)
Listed Waste (F,U,P, or K-listed)

Hazardous Waste Determination
Waste determinations may be made using either knowledge of the process or testing of a representative sample of the waste
Re-evaluated upon process change
Some facilities require annual re-testing
Samples must be collected on an “as generated” basis (prior to treatment mixture with other waste streams, etc.)
Characteristics tested for are:
Ignitibility, Corrosivity, Reactivity, Toxicity
Listed wastes – No testing needed

HW Identification Process
Is material a solid waste (SW)?
Is material excluded from SW or HW definition?
Is the waste a listed or characteristic hazardous waste?
Is the waste delisted?

HW Identification Process – Step 1
Is material a solid waste (SW)?
Does the material meet the definition of a solid waste?
If yes, move to question 2
If no, it is not a hazardous waste

HW Identification Process Step 2
Is material excluded from SW or HW definition?
If waste is not exempt or excluded, evaluate if it meets the HW definition

Hazardous Waste Definition
Solid Waste which:
Exhibits characteristic of a hazardous waste OR
Is Listed as hazardous waste

Hazardous Waste Exemptions
A number of exemptions exist for waste that would otherwise be considered hazardous
Exemption and exclusions are defined in 40 CFR 261.3 and 261.4 and include:
Domestic sewage
Industrial wastewater discharges covered by an NPDES permit
Several low toxicity, high volume wastes such as fly ash, cement kiln dust and certain drilling and mining wastes

HW Identification Process Step 3
Is the waste a listed or characteristic hazardous waste?

Listed Wastes
40 CFR 261 Subpart D
Four categories of listed wastes – F, U, P and K lists
EPA also includes a hazard code explaining why the waste was defined as hazardous at 261 Appendix VII

F, U, P, and K-Listed Waste
F-listed = non-source specific
F001–F005 is for certain spent solvents
K-Listed = waste from specific sources
U-listed wastes are discarded commercial chemical products that are toxic or display other hazardous characteristics
P-listed wastes are discarded commercial chemical products that are acutely toxic
U and P-listed wastes are relatively rare, except for labs and other applications where commercially pure grade chemicals are used

Waste (40 CFR 261.21 thru 24)
Ignitibility – waste code D001
Flash point < 140 degrees F (60 C)
Corrosivity - waste code D002
pH < 2 or >12.5
Reactivity - D003
Unstable, reacts violently with water, generates toxic fumes, readily capable of detonation at Standard Temperature and Pressure
Toxicity – waste codes D004 through D043
Exceed the TCLP threshold for a toxic constituent
TCLP = Toxicity Characteristics Leaching Procedure, a test method that is intended to represent how a waste would act if placed in a landfill
Solid Waste meeting any of these limits is a Characteristic Waste

HW Identification Process – Step 4
4. Is the waste delisted?
Listed wastes may changes as wastes are added or delisted
Waste handler may petition EPA for a site-specific delisting of a listed waste.
Delisting requirements are found at 40 CFR 260.22

Recycled Materials
Special subset of solid waste
When recycled, some materials are not hazardous wastes
Subject to less stringent regulatory controls
Recycling methodology determines whether waste is a regulated solid waste

Special Waste
A subcategory of solid waste that is not “hazardous waste” but requires specific handling.
Drums of industrial waste
Asbestos
Between landfill and generator to determine how to handle it
Must be tracked by location in the landfill
Waste that presents a threat to human health or the environment or a waste with inherent properties which make the disposal of the waste in a sanitary landfill difficult to manage
Special waste authorizations may be required

Hazardous Waste Mixtures
Never mix hazardous waste with nonhazardous waste without knowing the regulatory implications
A mixture of hazardous waste with non hazardous waste may be a hazardous waste
EPA developed the Mixture Rule to prevent facilities from mixing their hazardous wastes with nonhazardous solid wastes to avoid regulations
A mixture of any amount of a listed hazardous waste with a non-hazardous waste is a hazardous waste
Mixture rule applies to listed hazardous wastes, but not characteristic hazardous wastes.

Hazardous Waste Mixtures
Mixing a hazardous waste with a nonhazardous waste to achieve a nonhazardous waste is prohibited
However, a mixture of nonhazardous or exempt waste with characteristic hazardous waste is only defined as a hazardous waste if it exhibits one of more of the four hazardous characteristics
Ignitability
Corrosiveness
Reactivity
Toxicity

Containerized Materials
If a material in a container meets the definition of a hazardous waste when discarded, it must be treated as a hazardous waste even if it is still in its original container and has not been contaminated with anything

Empty Containers
Container may be considered a hazardous waste unless it is properly empty
Section 261.7 sets regulatory guidance for when a container is empty for the purposes of the Act

Waste Characterization Summary
EPA developed a four question test to use when characterizing waste
Hazardous waste may be a listed waste or a characteristic waste
Universal wastes are exempt from hazardous waste procedures as long as specific procedures are followed
Never mix hazardous waste with nonhazardous waste without knowing the regulatory impact

Hazardous Waste Generator
Generator status is based on quantity of waste generated on site in a calendar month
Generator status may change due to an unusual event or disposal requirement
Change in Generator status may trigger additional training, inspection and record keeping requirements

Hazardous Waste Generator
Three tiers of generators :
Fully Regulated -Large Quantity (LQG)
Small Quantity (SQG)
Conditionally Exempt Small Quantity (CESQG)
States generally follow RCRA classification scheme, but may set different standards.
Non-Generator Status generates NO hazardous wastes at any time

Hazardous Waste Generator (federal definition – states may vary)
Large Quantity (LQG) – Greater than 2,200 pounds of hazardous waste/month and/or greater than 2.2 pounds of acute hazardous waste/month. LQG can accumulate more than 13,200 pounds of HW on site at any time.
Small Quantity (SQG) – Between 220 and 2,200 pound of hazardous waste/month and up to 2.2 pounds of acute hazardous waste/month. SQG can accumulate between 2,200 and 13,200 pounds of HW on site at any time.
Conditionally Exempt Small Quantity (CESQG) – Less than 220 pounds of hazardous waste/month and up to 2.2 pounds of acute hazardous waste/month. CESQG can accumulate less than 2,200 pounds of HW on site at any time
Note: No averaging allowed on these quantities!

Hazardous Waste Tracking
List each hazardous waste generated at the facility on the Hazardous Waste Tracking Form
Whenever hazardous waste is generated, record the amount on the Form for that month
On the last day of the month, total the amount of hazardous waste generated on site that month
Determine generator status for the facility that month.
Confirm that facility is meeting the compliance requirements for that level of generator

Hazardous Waste Notification
EPA requires SQG and LQG to submit notification to the agency. A site specific identification number will be issued.
CESQG do not need to notify the agency, but transporters or disposal companies may require them to complete the notification
Use EPA Form 8700-12 Notification of Hazardous Waste Activity
Update 8700-12 Form with changes in hazardous waste streams

Hazardous Waste General Requirements
Generators must determine whether wastes are hazardous or non-hazardous
SQG and LQG must have an EPA identification number
Hazardous waste accumulation start date must be tracked from
When the waste is first generated
OR
When the quantity being accumulated in a container in a satellite area exceeds 55 gallons
Hazardous waste accumulation time allowed is based on generator status

Hazardous Waste General Requirements
Properly label with the words “Hazardous Waste” on each container or tank used to collect hazardous waste
Mark accumulation start date on each drum or container used to store HW. If satellite container, make date when it becomes full and move to storage area within 3 days
Only one container of up to 55 gallons of each separate waste stream allowed for each satellite accumulation area
Comply with container and/or tank storage requirements including inspections
Properly design facilities and communicate with local authorities as required by Preparedness and Prevention Measures
Designate Emergency coordinator(s)
Comply with Waste Minimization requirements

Large Quantity Generator
LQG generates greater than 2,200 pounds of hazardous waste/month and/or greater than 2.2 pounds of acute hazardous waste/month
Accumulation time is limited to 90 days
Prepare a Contingency Plan and emergency procedures
Document training of personnel
Submit Biennial Reports on even-number years
Comply with Air Emission Standards from 40 CFR part 265 Subpart CC

Small Quantity Generator
SQG generates between 220 and 2,200 pound of hazardous waste/month and up to 2.2 pounds of acute hazardous waste/month
Accumulation time is limited to 180 days, but may be extended to 270 days if wastes are to be shipped more than 200 miles for disposal
Accumulate less than 13,200 pounds of hazardous waste on site
Prepare emergency procedures
Train hazardous waste personnel on waste management and emergency/spill response procedures, but not required to be documented
Conditionally Exempt Small Quantity (CESQG) – Less than 220 pounds of hazardous waste/month and up to 2.2 pounds of acute hazardous waste/month

Conditionally Exempt Small Quantity Generator
CESQGs generate less than 220 pounds of hazardous waste/month and up to 2.2 pounds of acute hazardous waste/month
Never exceed a total on site accumulation of 2,200 pounds of hazardous waste
Accumulated hazardous wastes are delivered to an approved facility using a manifest
Follow proper labeling and inspection procedures
Personnel training addresses hazardous waste handling procedures and emergency response procedures

Episodic Generation
Generator status is determined on a calendar month basis
Generator status may change from one month to the next
Referred to as episodic generation
Required to comply with respective regulatory requirements for that particular month

State Specific Requirements
States have the authority to administer the RCRA program and may have differing or more stringent requirements, such as
Changes in generator categories and category requirements
Use of state manifests not allowed after September 2006 uniform manifest rule
More frequent and/or additional reports
Inclusion of additional materials, such as used oil, as hazardous waste

HW Generator Status Summary > 13,200 ≥ 2,200 Large Quantity Generator 2,200 – 13,200 < 2,200 Small Quantity Generator < 2,200 ≤ 220 Conditionally Exempt Small Quantity Generator Accumulation Limit (lbs at any time) Generation Rate (lbs/month) Generator Category

HW Storage Limits
Storage limit for Large Quantity Generators is 90 days
Storage limit for Small Quantity Generators is 180 days
May be extended to 270 days for SQG if wastes are to be shipped more than 200 miles for disposal
Storage allowed in containers or tanks
Tanks must meet RCRA requirements and are generally discouraged (especially USTs)
Tanks are defined as a stationary device designed to contain an accumulation of hazardous waste
Container means any portable device in which a material is stored, transported, treated, disposed of, or otherwise handled (totes)

HW Satellite Accumulation Containers
Satellite accumulation container
Any container ≤ 55 gallons used to accumulate hazardous waste (larger containers are not eligible)
Only one satellite container may be used at each point of generation (multiple points of generation allowed)
All satellite containers must be marked with the words “Hazardous Waste”
When full, satellite containers must be:
Marked with the accumulation start date and
Moved to 90-day storage area within 3 calendar days
Containers must be closed except when adding or removing waste
All containers and tanks used for storage must marked with the accumulation start date and the words “Hazardous Waste”

HW Storage Inspections
Documented weekly inspections must be conducted for all 90-day storage containers
Inspect for leaks or deterioration caused by corrosion
Documented daily inspections must be conducted for all 90-day storage tanks
Inspect discharge control equipment, monitoring equipment, level in the tank, and construction materials
Secondary containment must be provided

HW Disposal
SQG and LQG must ship all hazardous waste from the facility to a permitted Treatment, Storage or Disposal Facility (TSDF)
EPA Identification number required
A hazardous waste manifest must be used for all shipments of hazardous waste
Except where tolling agreement exists (e.g., Safety Kleen parts washer waste)

HW Training
LQGs must have a written Contingency Plan that includes:
A description of the actions facility personnel must take to respond to a release
A description of the arrangements with local emergency services (fire, police, hospital)
Designation of primary and secondary emergency coordinators
A list of all emergency equipment on site & capabilities
An evacuation plan
Copies of the plan must be maintained at the facility and submitted to local police, fire, and hospital
Anyone who handles hazardous waste must be trained annually on the contents of the Contingency Plan and the proper handling of hazardous waste

HW Record Keeping
Maintain the following for at least 3 years:
Waste analyses, test results or information supporting waste determinations
Storage inspection records
Personnel training records
Biennial reports and Exception reports (LQGs only)
SQG and LQG must keep current emergency contact information posted near a telephone

HW Reporting
Large Quantity Generators are required to submit a report (Form 8700-13A) by March 1 of each even-numbered years for the previous years manifested shipments
If EPA runs the program in that state, the report is submitted to the appropriate EPA Regional Office
States may have additional reporting requirements

Common HW Violations noted during inspections
Not marking containers with “Hazardous Waste”
Not marking containers with accumulation start date
Open container while not adding/removing waste
Incomplete or missing inspection records
Inspection records not signed and dated
Incomplete or missing training records
Out dated or missing manifest records
Failure to properly characterize waste

HW Disposal Requirements
Properly package, label, and mark each drum or container for transport off-site
Prepare a manifest for all transported hazardous waste
Comply with land disposal restrictions for certain wastes
Use a RCRA-permitted transporter for off-site shipment to a RCRA-permitted disposal facility
Maintain records of manifests, exception reports, waste profiles, and test results

HW Generator Requirements – Summary
Generator status is determined by the amount and type of waste generated at site and the amount of waste accumulated on site at any time
There are specific requirements for each type of generator covering
Storage and Accumulation amounts and time limits
Inspections, Training and Reporting
Transport, Disposal and Record Keeping

Hazardous Waste Manifest - Overview
EPA Form 8700-22
Owner fills out manifest form describing waste and designated recipient and alternative recipient
Transporter signs manifest and leaves copy with generator
Recipient signs manifest and sends copy of manifest back to generator
If signed copy of manifest is not received from facility within 45 days (LGQ) or 60 days (SQG) of transport, follow exception reporting requirements

Waste Manifesting Waste Generated (Create Manifest) Generator (keep green copy) Transporter (keep yellow copy) Disposal Facility (keep pink copy) Returned to Generator (all signatures) Uniform Hazardous Waste Manifest “ Cradle to Grave”

Hazardous Waste Manifest
Generator’s representative certifies:
That waste is properly marked, packed, classified, and labeled
Program in place to reduce volume and toxicity of waste (LQG)
Selected Treatment /Storage /Disposal method is best available method (LQG)

Treatment, Storage and Disposal Facilities
Last link in cradle-to-grave hazardous waste management system
40 CFR Parts 264 and 265
Requirements are more extensive than standards for generators and transporters
Two categories:
Permitted (new)
Interim Status (existing)

HW Manifest Summary
Use EPA Form 8700-22 or appropriate state manifest for any hazardous waste disposal
HW Generator signs manifest to certify waste is properly marked, packed, classified, and labeled
Details of HW Manifest will be covered in Waste Management – Level 2 Module

Summary – Waste Management
Definition of Solid Waste
Definition of Hazardous Waste
Characteristic
Listed
Generator Status and Requirements
Waste Manifests
Special Solid Waste Procedures

Universal Waste
Category of hazardous waste that is exempt from hazardous waste requirements if specified handling and recycling practices are followed (40 CFR 273)
Waste is shipped by approved universal waste handlers
Includes:
Batteries
Recalled pesticides
Mercury thermostats
Lamps (fluorescent bulbs & tube)

Universal Waste Handlers
Universal Waste Handlers, two types
First type –
Person who generates or creates, universal waste or
Contractors or repair people
Second type –
Person who receives universal waste from generates or other handlers
Universal waste handlers accumulate universal waste, but do not treat, recycle, or dispose of the waste

Universal Waste Regulations
Two sets of regulations
Small quantity handlers of universal waste (SQHUW)
Accumulates less than 5,000 kilograms (11,000 lbs)
Large quantity handlers of universal waste (LQHUW)
Accumulates 5,000 kilograms or more
At any one-time
Designation retained through the end of the calendar year

Small Quantity Handlers UW
No notification to accumulate UW
Waste Management
Store in closed, structurally sound, and compatible containers
Labeling
Mark containers
“ Universal Waste – Batteries”, or
“ Waste – Batteries”, or
“ Used – Batteries”
Accumulation time – 1 year, mark the earliest date of any UW in the container
Employee Training – “Inform” all employees who handle or have responsibility for managing UW
Proper Handling, and
Appropriate emergency procedures

Large Quantity Handlers UW
Submit notification to accumulate UW, and obtain an EPA ID Number
Waste Management
Store in closed, structurally sound, and compatible containers
Labeling
Mark containers
“ Universal Waste – Batteries”, or
“ Waste – Batteries”, or
“ Used – Batteries”
Accumulation time – 1 year, mark the earliest date of any UW in the container
Employee Training – “Ensure” all employees are thoroughly familiar with
Proper Handling, and
Emergency procedures

Lead Acid Batteries
Two managing options:
Per 40 CFR 273.2 as “Universal Waste” or
Per 40 CFR 266.80 (Subpart G)
If you generate, collect, transport, store or regenerate lead-acid batteries for reclamation purposes,
Exemption from certain hazardous waste management requirements
Primarily used for the reclamation of spent “automotive” lead-acid batteries
Must determine which one of the five applicable requirements under 40 CFR 266.80
No labeling requirements

UW - Summary
Generators responsibility to determine if the waste should be managed as hazardous waste or UW
If managed as UW, then it’s the generators responsibility for
Notification if required
Waste Management
Labeling
Accumulation time
Employee Training

Understanding universal & hazardous waste

by WasteCap_Nebraska on Jul 27, 2011

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Understanding universal & hazardous waste — Presentation Transcript

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