HHO - Waste Handling 12-2019

1. Waste Handling and Storage December 2019 HAVERHILL OPERATIONS

2. • LQG/Spill Response General Requirements • Hazardous Waste – Types – Storage – Labeling – Accumulation – Spills • Non – Hazardous Waste – Types • Universal Waste – Types – Storage – Labeling – Accumulation • Used Oil – Types – Storage – Labeling Training Outline

3. General Requirements • RCRA: Resource Conservation and Recovery Act – Hazardous Waste Onsite Management – All employees are trained to handle/manage hazardous waste

4. General Requirements • RCRA: Resource Conservation and Recovery Act – Hazardous Waste Onsite Management – All employees are trained to handle/manage hazardous waste • CERCLA: Comprehensive Environmental Response, Compensation, and Liability Act – Hazardous Substance and Pollutant Cleanup – Employees receive HAZWOPER Awareness training to respond to Incidental Hazardous Waste spills – HHO contracts Heritage to respond to Emergency spills

5. General Requirements • RCRA: Resource Conservation and Recovery Act – Hazardous Waste Onsite Management – All employees are trained to handle/manage hazardous waste • CERCLA: Comprehensive Environmental Response, Compensation, and Liability Act – Hazardous Substance and Pollutant Cleanup – Employees receive HAZWOPER Awareness training to respond to Incidental Hazardous Waste spills – HHO contracts Heritage to respond to Emergency spills • DOT: Department of Transportation – Transport of Hazardous Materials (HazMats) – Employees are trained based on their job requirements

6. Hazardous Waste

7. LQG Requirements HHO Haz Waste, Large Quantity Generator (LQG) Stored on secondary containment Containers closed unless in use Disposed of @ RCRA C Landfill Wear proper PPE when handling any waste Wash hands after handling wastes Labeled and dated Offsite w/i 90 days Reportable Quantities reported Do not smoke, eat, or drink while handling wastes Based on amount of waste generated monthly Amount of material released to the air, water, or land Except for Satellite Accumulation

8. LQG Requirements HHO Haz Waste, Large Quantity Generator (LQG) On containment, @ decon pad Containers closed unless in use Disposed of @ RCRA C Landfill Wear proper PPE when handling any waste Wash hands after handling wastes Labeled and dated Offsite w/i 90 days Reportable Quantities reported Do not smoke, eat, or drink while handling wastes Based on amount of waste generated monthly Amount of material released to the air, water, or land Except for Satellite Accumulation

17. • HRSG Wastes – HRSG Wash Water – HRSG Ash – HRSG Ash Covered Boiler Tubes • Flammables • Corrosives • If you’re not sure if a waste is hazardous, ask the Environmental Manager! Types of Haz Waste

18. Emergency Coordinators • Primary Coordinator – Diana Starkweather • Secondary Coordinator – Don Reeves

19. 90 Day-Storage aka Decon Pad

20. 90 Day-Storage aka Decon Pad • Small containers go on back of pad • Liquids must go on spill pallet

21. 90 Day-Storage aka Decon Pad • Small containers go on back of pad • Liquids must go on spill pallet • Frac containers & roll offs on front of pad

22. • Place directly into roll off or drum • Do NOT overfill roll offs • Close all roll offs when not in use HRSG Ash & Tubes What’s wrong here?

23. • Place directly into roll off or drum • Do NOT overfill roll offs • Close all roll offs when not in use HRSG Ash & Tubes What’s wrong here? Tubes are not in a roll off Ash is also present on pad Roll off is overfilled & open Wastes are not labeled

24. Contractor HRSG Cleaning Reqs • HRSG Cleaning – Place temporary containments to prevent spills • Under the first expansion joint of cold duct after HRSG • Under the economizer – Tarps around HRSGs • Sides of HRSG • Extending down to pad – Place absorbents between economizer & PCV to prevent leak-through to cold duct • Roll offs – Build berms under roll offs to prevent incidental spills during transfer – Ensure they are lined before putting waste in them

25. HRSG Outage Checklist • Before the start of cleaning  All containments are in place

26. HRSG Outage Checklist • Before the start of cleaning  All containments are in place  Hose connections are secure and won’t leak

27. HRSG Outage Checklist • Before the start of cleaning  All containments are in place  Hose connections are secure and won’t leak  Valves on trucks/HRSG containments are in proper position

28. HRSG Outage Checklist • Before the start of cleaning  All containments are in place  Hose connections are secure and won’t leak  Valves on trucks/HRSG containments are in proper position • During Cleaning  HRSG wash water does not get on ground

29. HRSG Outage Checklist • Before the start of cleaning  All containments are in place  Hose connections are secure and won’t leak  Valves on trucks/HRSG containments are in proper position • During Cleaning  HRSG wash water does not get on ground  Visually verify that no wash water is going to the ditch

30. HRSG Outage Checklist • Before the start of cleaning  All containments are in place  Hose connections are secure and won’t leak  Valves on trucks/HRSG containments are in proper position • During Cleaning  HRSG wash water does not get on ground  Visually verify that no wash water is going to the ditch  Any clean discharge water goes to the ground, not the HRSG

31. HRSG Outage Checklist • Before the start of cleaning  All containments are in place  Hose connections are secure and won’t leak  Valves on trucks/HRSG containments are in proper position • During Cleaning  HRSG wash water does not get on ground  Visually verify that no wash water is going to the ditch  Any clean discharge water goes to the ground, not the HRSG  Containers are labeled as soon as waste is placed in them

32. HRSG Outage Checklist • Before the start of cleaning  All containments are in place  Hose connections are secure and won’t leak  Valves on trucks/HRSG containments are in proper position • During Cleaning  HRSG wash water does not get on ground  Visually verify that no wash water is going to the ditch  Any clean discharge water goes to the ground, not the HRSG  Containers are labeled as soon as waste is placed in them  Containers are closed when not in use

33. HRSG Outage Checklist • Before the start of cleaning  All containments are in place  Hose connections are secure and won’t leak  Valves on trucks/HRSG containments are in proper position • During Cleaning  HRSG wash water does not get on ground  Visually verify that no wash water is going to the ditch  Any clean discharge water goes to the ground, not the HRSG  Containers are labeled as soon as waste is placed in them  Containers are closed when not in use  All bows must be in place on roll off

34. HRSG Outage Checklist • Before the start of cleaning  All containments are in place  Hose connections are secure and won’t leak  Valves on trucks/HRSG containments are in proper position • During Cleaning  HRSG wash water does not get on ground  Visually verify that no wash water is going to the ditch  Any clean discharge water goes to the ground, not the HRSG  Containers are labeled as soon as waste is placed in them  Containers are closed when not in use  All bows must be in place on roll off  All latches must be tightened

35. HRSG Outage Checklist • Before the start of cleaning  All containments are in place  Hose connections are secure and won’t leak  Valves on trucks/HRSG containments are in proper position • During Cleaning  HRSG wash water does not get on ground  Visually verify that no wash water is going to the ditch  Any clean discharge water goes to the ground, not the HRSG  Containers are labeled as soon as waste is placed in them  Containers are closed when not in use  All bows must be in place on roll off  All latches must be tightened • After Cleaning  Water collected from pad is placed in frac tank

36. HRSG Outage Checklist • Before the start of cleaning  All containments are in place  Hose connections are secure and won’t leak  Valves on trucks/HRSG containments are in proper position • During Cleaning  HRSG wash water does not get on ground  Visually verify that no wash water is going to the ditch  Any clean discharge water goes to the ground, not the HRSG  Containers are labeled as soon as waste is placed in them  Containers are closed when not in use  All bows must be in place on roll off  All latches must be tightened • After Cleaning  Water collected from pad is placed in frac tank  Decon Pad and frac tank are decontaminated after Outage Season

37. • Generator info Labeling

38. • Generator info • Contents Labeling

39. • Generator info • Contents • Words “Hazardous Waste” Labeling

40. • Generator info • Contents • Words “Hazardous Waste” • Date the waste was generated Labeling

41. • Generator info • Contents • Words “Hazardous Waste” • Date the waste was generated • Hazards of wastes – Can be hand written Labeling Arsenic Cadmium Chromium Lead E x a m p l e H a z a r d s

42. Pop Quiz • What is wrong with this picture?

43. Pop Quiz • What is wrong with this picture? • The Roll Offs don’t have berms for incidental spills • They are not labeled

44. Hazardous Waste Spills Incidental Spills •No significant safety/health hazards in immediate vicinity •No potential to become an emergency •Limited in quantity, exposure potential, or toxicity •Material has minor safety or health hazards •Not compounded by another incident such as injury, fire Haz Waste Emergency •Goes outside immediate release area or requires evacuation •Potential to pose IDLH condition or high exposure to toxic substances •Exposure limits could be easily exceeded •Serious threat of fire or explosion •Imminent danger •Situation is unclear or it’s uncertain if employees can handle severity of hazard w/ available PPE/equipment HAZWOPER awareness level can respond w/ available equip.

50. Hazardous Waste Spills Incidental Spills •No significant safety/health hazards in immediate vicinity •No potential to become an emergency •Limited in quantity, exposure potential, or toxicity •Material has minor safety or health hazards •Not compounded by another incident such as injury, fire Haz Waste Emergency •Goes outside immediate release area or requires evacuation •Potential to pose IDLH condition or high exposure to toxic substances •Exposure limits could be easily exceeded •Serious threat of fire or explosion •Imminent danger •Situation is unclear or it’s uncertain if employees can handle severity of hazard w/ available PPE/equipment HAZWOPER awareness level can respond w/ available equip. Only emergency response contractor can respond

57. Satellite Accumulation • Only 1 satellite accumulation drum for each accumulation area – HRSG Ash @ HRSG 11/12 – Aerosol Cans @ Maint. Shop • When Drum is full – 90 day clock starts • Date the label • Move drum to Haz Waste Storage

58. Can you have 1 satellite accumulation drum for each Ash Hopper at HRSG 11? Pop Quiz

59. Can you have 1 satellite accumulation drum for each Ash Hopper at HRSG 11? No. You can only have 1 drum in each satellite accumulation area. Pop Quiz

60. This satellite accumulation drum is full & is dated August 13. Today is August 17. What do you have to do? Pop Quiz

61. This satellite accumulation drum is full & is dated August 13. Today is August 17. What do you have to do? Pop Quiz Swap the vapor trap lid to a new drum and move the full drum to the Decon Pad.

62. Non-Hazardous Wastes

63. • Special Wastes have unique handling, transportation, or disposal requirements Special Wastes

64. • Special Wastes have unique handling, transportation, or disposal requirements • Bulk piles north of Laydown Yard – Refractory – Storm water ditch clean out – Settling Basin Cleanout Special Wastes

65. • Other materials stored in the Debris Piles • Clean fill dirt • Concrete • Asphalt • Carbon Debris Piles

66. • Other materials stored in the Debris Piles • Clean fill dirt • Concrete • Asphalt • Carbon • Is it okay to mix refractory with carbon or clean fill dirt? Debris Piles

67. • Other materials stored in the Debris Piles • Clean fill dirt • Concrete • Asphalt • Carbon • Is it okay to mix refractory with carbon or clean fill dirt? Debris Piles • No. Refractory is a special wastes and must be separate from other materials. Carbon can be sold and clean fill dirt may be used in a project.

68. • Generated during SO2 removal • Transported to landfill each day – Used to solidify liquid wastes Fly Ash

69. • Scrap Metal • Cardboard • Plastic bottles • Paper Recycling

70. You go to put a lead acid battery in the proper container and see this. What do you do? Recycling • Lead Acid Batteries Storage Bin – Behind Warehouse – Stack in a single layer – Tape terminals

71. You go to put a lead acid battery in the proper container and see this. What do you do? Unstack the batteries to make a single layer Notify EHS that the container is full Tape each battery terminal Recycling • Lead Acid Batteries Storage Bin – Behind Warehouse – Stack in a single layer – Tape terminals

72. • Solvents are recycled periodically • Operating Instructions must be posted • The parts washer must be closed when not in use Parts Washer

73. • Solvents are recycled periodically • Operating Instructions must be posted • The parts washer must be closed when not in use Parts Washer

74. • Do not move trash receptacles • Tippers (below) can be moved for projects/maintenance – You must dump them into dumpster for trash to be picked up Regular Trash

75. • Use the oil filter crusher to remove oil from old filters • Crushed oil filters do not contain oil – Place Crushed Oil Filters in scrap metal bin • ***This is new recommendation from OEPA, so sign does not show this*** Regular Trash Ok to put in scrap metal bin

76. 1) Drain residual oil from buckets into Used Oil Tank Regular Trash 2) When empty, put in trash

77. Universal Waste

78. Types • Batteries

79. Types • Batteries • Mercury Containing Lamps

80. Types • Batteries • Mercury Containing Lamps • Aerosol Cans

81. • Universal Waste Batteries – Battery Buckets • Admin Warehouse • Hourly Lunch Room • Power Island • Warehouse • Maintenance Shop – Close buckets when not in use • Terminals must be taped – Can cause fire – Required by law! Storage

82. • Universal Waste Batteries – Battery Buckets • Admin Warehouse • Hourly Lunch Room • Power Island • Warehouse • Maintenance Shop – Close buckets when not in use • Terminals must be taped – Can cause fire – Required by law! Storage • Aerosol Cans • Drum in Maintenance Bldg. • Vapor Lock Lid • Use as much as possible before placing in drum

83. • Universal Waste Batteries – Battery Buckets • Admin Warehouse • Hourly Lunch Room • Power Island • Warehouse • Maintenance Shop – Close buckets when not in use • Terminals must be taped – Can cause fire – Required by law! • Mercury Bulbs • Properly sized box in ENV Conex • Seal liner with rubber band • Broken bulbs are haz waste • Clean up immediately Storage • Aerosol Cans • Drum in Maintenance Bldg. • Vapor Lock Lid • Use as much as possible before placing in drum

84. • Universal Waste Batteries – Battery Buckets • Admin Warehouse • Hourly Lunch Room • Power Island • Warehouse • Maintenance Shop – Close buckets when not in use • Terminals must be taped – Can cause fire – Required by law! • Mercury Bulbs • Properly sized box in ENV Conex • Seal liner with rubber band • Broken bulbs are haz waste • Clean up immediately Storage • Aerosol Cans • Drum in Maintenance Bldg. • Vapor Lock Lid • Use as much as possible before placing in drum

85. • Contents Labeling

86. • Contents • Words “Universal Waste” Labeling

87. • Contents • Words “Universal Waste” • Date 1st item was put in container Labeling

88. What is wrong with this picture? Pop Quiz

89. What is wrong with this picture? The battery bucket is not sealed Pop Quiz

90. Which of the bulb containers is closed? Pop Quiz

91. Which of the bulb containers is closed? Bag on right is sealed w/ rubber band Bag on left is not sealed If the box is open, but the bag is sealed, it IS closed! Pop Quiz

92. You notice this trash can near FGD 1. What should you do? Pop Quiz

93. You notice this trash can near FGD 1. What should you do? Pop Quiz Place cans in Aerosol Can drum

94. Used Oil

95. Oily Water Supervised Release • Release water only from containments with oil-filled equipment only – If there is any liquid other than water or oil in the containment, do not drain Unlock containment valve •Keys in Turn Mgr Office Open Valve •Do not leave immediate area Watch the water draining •Do not drain any oil! Leave 1” of water above valve •Ensures no oil is drained Close & lock valve • Return key to Turn Mgr

96. Supervised Release • Release water only from containments with oil-filled equipment only – If there is any liquid other than water or oil in the containment, do not drain Unlock containment valve •Keys in Turn Mgr Office Open Valve •Do not leave immediate area Watch the water draining • Do not drain any oil! Leave 1” of water above valve • Ensures no oil is drained Close & lock valve • Return key to Turn Mgr

97. Supervised Release • Release water only from containments with oil-filled equipment only – If there is any liquid other than water or oil in the containment, do not drain Unlock containment valve •Keys in Turn Mgr Office Open Valve •Do not leave immediate area Watch the water draining •Do not drain any oil! Leave 1” of water above valve • Ensures no oil is drained Close & lock valve • Return key to Turn Mgr

98. Supervised Release • Release water only from containments with oil-filled equipment only – If there is any liquid other than water or oil in the containment, do not drain Unlock containment valve •Keys in Turn Mgr Office Open Valve •Do not leave immediate area Watch the water draining •Do not drain any oil! Leave 1” of water above valve •Ensures no oil is drained Close & lock valve • Return key to Turn Mgr

99. Supervised Release • Release water only from containments with oil-filled equipment only – If there is any liquid other than water or oil in the containment, do not drain Unlock containment valve •Keys in Turn Mgr Office Open Valve •Do not leave immediate area Watch the water draining •Do not drain any oil! Leave 1” of water above valve •Ensures no oil is drained Close & lock valve •Return key to Turn Mgr

100. Supervised Release • Release water only from containments with oil-filled equipment only – If there is any liquid other than water or oil in the containment, do not drain Notify EHS Dept. if containment needs vacc’d out

101. • Used Oil Pad Storage

102. • Used Oil Pad – 55 gallon drums – Used Oil Absorbent/Oily Rags Drum Storage

103. • Used Oil Pad – 55 gallon drums – Used Oil Absorbent/Oily Rags Drum – Totes Storage

104. • Used Oil Pad – 55 gallon drums – Used Oil Absorbent/Oily Rags Drum – Totes – 5 Gallon Buckets Storage

105. • Used Oil Pad – 55 gallon drums – Used Oil Absorbent/Oily Rags Drum – Totes – 5 Gallon Buckets – Used Oil Tank Storage

106. • Used Oil Pad – 55 gallon drums – Used Oil Absorbent/Oily Rags Drum – Totes – 5 Gallon Buckets – Used Oil Tank – CRP Paks Storage

107. • Used Oil Pad – 55 gallon drums – Used Oil Absorbent/Oily Rags Drum – Totes – 5 Gallon Buckets – Used Oil Tank – CRP Paks Storage ALWAYS close containers when not in use

108. • Oily Debris Roll Off – Oil/Fuel soaked solids Storage

109. • Words “Used Oil” Labeling

110. What are considered oily/fuel debris? Pop Quiz

111. What are considered oily/fuel debris? Pop Quiz Materials from Oil/Fuel spill cleanups Used Absorbents Oily/Fuel Soaked Rags Oil/Fuel-contaminated soil

112. What is wrong with this picture? Pop Quiz

113. What is wrong with this picture? Pop Quiz All containers need labels Empty buckets can be thrown in trash Full oil buckets need to be drained into Used Oil Tank, then thrown in trash

114. While moving a Used Oil drum to the Used Oil Pad, you notice this. What do you do? Pop Quiz

115. While moving a Used Oil drum to the Used Oil Pad, you notice this. What do you do? Close the lid on the Used Oil Tank Place hoses over containment Pop Quiz

HHO - Waste Handling 12-2019

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