HHO - Waste Handling 12-2019

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Waste Handling andStorage December 2019 HAVERHILL OPERATIONS

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• LQG/Spill ResponseGeneral 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

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

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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

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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

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Hazardous Waste

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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

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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

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• 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

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Emergency Coordinators • PrimaryCoordinator – Diana Starkweather • Secondary Coordinator – Don Reeves

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90 Day-Storage akaDecon Pad

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90 Day-Storage akaDecon Pad • Small containers go on back of pad • Liquids must go on spill pallet

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

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

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• Place directlyinto 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

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Contractor HRSG CleaningReqs • 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

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

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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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• Generator info Labeling

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• Generator info •Contents Labeling

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

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

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• 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

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Pop Quiz • Whatis wrong with this picture?

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

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Hazardous Waste Spills Incidental Spills •Nosignificant 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.

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Hazardous Waste Spills Incidental Spills •Nosignificant 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

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Satellite Accumulation • Only1 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

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Can you have1 satellite accumulation drum for each Ash Hopper at HRSG 11? Pop Quiz

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Can you have1 satellite accumulation drum for each Ash Hopper at HRSG 11? No. You can only have 1 drum in each satellite accumulation area. Pop Quiz

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

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This satellite accumulationdrum 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.

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Non-Hazardous Wastes

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• Special Wasteshave unique handling, transportation, or disposal requirements Special Wastes

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

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• Other materialsstored in the Debris Piles • Clean fill dirt • Concrete • Asphalt • Carbon Debris Piles

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

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• Other materialsstored 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.

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• Generated duringSO2 removal • Transported to landfill each day – Used to solidify liquid wastes Fly Ash

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• Scrap Metal •Cardboard • Plastic bottles • Paper Recycling

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You go toput 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

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You go toput 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

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• Solvents arerecycled periodically • Operating Instructions must be posted • The parts washer must be closed when not in use Parts Washer

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• Solvents arerecycled periodically • Operating Instructions must be posted • The parts washer must be closed when not in use Parts Washer

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• Do notmove trash receptacles • Tippers (below) can be moved for projects/maintenance – You must dump them into dumpster for trash to be picked up Regular Trash

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• Use theoil 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

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1) Drain residualoil from buckets into Used Oil Tank Regular Trash 2) When empty, put in trash

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Universal Waste

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Types • Batteries

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Types • Batteries • MercuryContaining Lamps

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Types • Batteries • MercuryContaining Lamps • Aerosol Cans

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• Universal WasteBatteries – 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

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• Universal WasteBatteries – 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

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• Universal WasteBatteries – 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

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• Universal WasteBatteries – 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

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• Contents Labeling

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• Contents • Words“Universal Waste” Labeling

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

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What is wrongwith this picture? Pop Quiz

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What is wrongwith this picture? The battery bucket is not sealed Pop Quiz

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Which of thebulb containers is closed? Pop Quiz

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Which of thebulb 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

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You notice thistrash can near FGD 1. What should you do? Pop Quiz

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

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Used Oil

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Oily Water SupervisedRelease • 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

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Supervised Release • Releasewater 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

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Supervised Release • Releasewater 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

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Supervised Release • Releasewater 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

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Supervised Release • Releasewater 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

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Supervised Release • Releasewater 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

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• Used OilPad Storage

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• Used OilPad – 55 gallon drums – Used Oil Absorbent/Oily Rags Drum Storage

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• Used OilPad – 55 gallon drums – Used Oil Absorbent/Oily Rags Drum – Totes Storage

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

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

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

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• Used OilPad – 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

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• Oily DebrisRoll Off – Oil/Fuel soaked solids Storage

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• Words “UsedOil” Labeling

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What are consideredoily/fuel debris? Pop Quiz

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

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What is wrongwith this picture? Pop Quiz

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What is wrongwith 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

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

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While moving aUsed 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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