Understanding universal & hazardous waste
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Understanding universal & hazardous waste

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Understanding universal & hazardous waste Understanding universal & hazardous waste Presentation Transcript

  • 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
    • Use a RCRA-permitted transporter for off-site shipment to a RCRA-permitted disposal facility
  • 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
    • Use a RCRA-permitted transporter for off-site shipment to a RCRA-permitted disposal facility
    • 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