Annual RCRA Hazardous Annual RCRA Hazardous Waste Training ProgramWaste Training Program

CFR 40CFR 40

• EPA has implemented:EPA has implemented:

• Regulations for Identification of wastesRegulations for Identification of wastes

• Performance standards for generatorsPerformance standards for generators

• Hazardous waste facility permit programHazardous waste facility permit program

• Mandated annual training for employees Mandated annual training for employees who handle, process or may regularly be who handle, process or may regularly be exposed to hazardous wasteexposed to hazardous waste

Training ObjectivesTraining Objectives

• Understand types of waste generatorsUnderstand types of waste generators• Define hazardous wastesDefine hazardous wastes• Describe proper handling and storage of Describe proper handling and storage of

hazardous wastehazardous waste• Select proper waste containersSelect proper waste containers• Label and mark waste containersLabel and mark waste containers• Discuss truck loading requirementsDiscuss truck loading requirements• Complete paperwork for waste shipmentComplete paperwork for waste shipment• Response to emergenciesResponse to emergencies

Types of GeneratorsTypes of Generators

• Large quantity –generates Large quantity –generates >1000kg(2205 lbs) in any month>1000kg(2205 lbs) in any month

• Small quantity - generates Small quantity - generates <1000kg(2205 lbs) in any calendar <1000kg(2205 lbs) in any calendar month (approx 5 drums)month (approx 5 drums)

Never accumulates >6000kg on siteNever accumulates >6000kg on site* Very small quantity – generates < * Very small quantity – generates <

100kg per month; never >1000kg on 100kg per month; never >1000kg on sitesite

SQG MustSQG Must

• Obtain a USEPA identification numberObtain a USEPA identification number• Identify Hazardous wastesIdentify Hazardous wastes• Keep records of wastesKeep records of wastes• Inspect waste containers regularly for Inspect waste containers regularly for

damage; document these inspectionsdamage; document these inspections• Dispose of waste through licensed Dispose of waste through licensed

waste haulers/facilitieswaste haulers/facilities• Fill-out and retain proper shipping Fill-out and retain proper shipping

paperspapers

What is a hazardous waste?What is a hazardous waste?

• A solid waste, or combination of solid wastes, A solid waste, or combination of solid wastes, which because of its quantity, concentration, which because of its quantity, concentration, or physical, chemical, or infectious or physical, chemical, or infectious characteristics may:characteristics may:

• Cause or significantly contribute to an Cause or significantly contribute to an increase in mortality or an increase in serious increase in mortality or an increase in serious irreversible, or incapacitating reversible irreversible, or incapacitating reversible illness; orillness; or

• Pose a substantial present or potential hazard Pose a substantial present or potential hazard to human health or the environment when to human health or the environment when improperly treated, stored, transported, improperly treated, stored, transported, disposed of, or otherwise managed.disposed of, or otherwise managed.

What is a hazardous waste? What is a hazardous waste? ContdContd

• Listed Wastes – automatically hazardous if it Listed Wastes – automatically hazardous if it is named on RCRA list (>400 chemicals)is named on RCRA list (>400 chemicals)

• Characteristic Waste- waste isCharacteristic Waste- waste is

• Ignitable – easily combustible/flammableIgnitable – easily combustible/flammable

• Corrosive - pH 2.0 or less;12.5 or moreCorrosive - pH 2.0 or less;12.5 or more

• Reactive – unstable or reacts violently with Reactive – unstable or reacts violently with water or other materialswater or other materials

• Toxic – if extract has heavy metals, Toxic – if extract has heavy metals, pesticidespesticides

What is a Hazardous Waste? What is a Hazardous Waste? contdcontd

• Acutely Hazardous wastes- these are Acutely Hazardous wastes- these are so hazardous (primarily some so hazardous (primarily some pesticides or dioxin-containing pesticides or dioxin-containing wastes) that generation of 2.2 lbs or wastes) that generation of 2.2 lbs or having that much on-site would be having that much on-site would be enough to categorize a company as a enough to categorize a company as a Large quantity generatorLarge quantity generator

RBP wasteRBP waste

• RBP is a small quantity generatorRBP is a small quantity generator

• Primary hazardous waste is solvent from Primary hazardous waste is solvent from tank washout. This is collected at a site tank washout. This is collected at a site other than the storage site. Suitable other than the storage site. Suitable container for flammable liquid is a steel container for flammable liquid is a steel drum.drum.

• Satellite – waste drum collection in Chem Satellite – waste drum collection in Chem Mix#1 area; maximum 55 galsMix#1 area; maximum 55 gals

• Storage- Flammable Storage Room Storage- Flammable Storage Room

Ignitable WastesIgnitable Wastes

• Code D001 if:Code D001 if:

• A liquid with flash point <140F; A liquid with flash point <140F; exception is an aqueous solution with exception is an aqueous solution with <24% alcohol<24% alcohol

• A non-liquid capable at 77F and 760mm A non-liquid capable at 77F and 760mm pressure of causing fire due to friction, pressure of causing fire due to friction, absorption of water or spontaneous absorption of water or spontaneous reaction and, if ignited, burns vigorouslyreaction and, if ignited, burns vigorously

Ignitable Wastes continuedIgnitable Wastes continued

• It is an oxidizer, such as chlorate, It is an oxidizer, such as chlorate, permanganate, inorganic peroxide, permanganate, inorganic peroxide, or a nitrate that yields oxygen to or a nitrate that yields oxygen to stimulate combustion of organic stimulate combustion of organic materialmaterial

RBP WasteRBP Waste

• Corrosive wastes – unusable raw Corrosive wastes – unusable raw materials and/or rejected/obsolete materials and/or rejected/obsolete products that cannot be utilized. products that cannot be utilized. Suitable containers are those not Suitable containers are those not damaged by corrosive nature of waste.damaged by corrosive nature of waste.

• Storage- return areaStorage- return area• A waste is not a waste until RBP makes A waste is not a waste until RBP makes

the determination that we cannot use it.the determination that we cannot use it.

Corrosive Wastes NRCorrosive Wastes NR

• EPA waste code D002EPA waste code D002

• Classed as corrosive waste if:Classed as corrosive waste if:

• Aqueous solution wiyh pH<2 or Aqueous solution wiyh pH<2 or >12.5, or>12.5, or

• Liquid that corrodes plain carbon Liquid that corrodes plain carbon steel with carbon content of 0.20% at steel with carbon content of 0.20% at rate >6.35mm/0.25” year at 55C.rate >6.35mm/0.25” year at 55C.

Reactive Waste IfReactive Waste If• ( Code D003 )( Code D003 )

• Reacts violently with water, orReacts violently with water, or

• Forms potentially explosive mixtures Forms potentially explosive mixtures with water, orwith water, or

• Normally unstable and readily undergoes Normally unstable and readily undergoes violent change without detonating, orviolent change without detonating, or

• When mixed with water generates toxic When mixed with water generates toxic gases sufficient to be danger to humansgases sufficient to be danger to humans

Reactive Waste continuedReactive Waste continued

• If a cyanide which when exposed to If a cyanide which when exposed to pH between 2-12.5 can generate pH between 2-12.5 can generate toxic gases.toxic gases.

• example would be the cyanide example would be the cyanide locked in cabinet in Brad’s area. If we locked in cabinet in Brad’s area. If we decided we couldn’t use it or find a decided we couldn’t use it or find a user this would be disposed of under user this would be disposed of under this hazardous waste codethis hazardous waste code

Toxic WastesToxic Wastes

• EPA waste codes D004-D043EPA waste codes D004-D043

• Specific test method used to Specific test method used to determine level of listed hazardous determine level of listed hazardous material. Examples are mercury, material. Examples are mercury, chromium, lead, pesticides, benzenechromium, lead, pesticides, benzene

Waste TreatmentWaste Treatment

• RBP has no permit as a waste RBP has no permit as a waste treatment facilitytreatment facility

• Elementary neutralization of a waste Elementary neutralization of a waste whose only hazard is pH based is whose only hazard is pH based is allowed as long as:allowed as long as:

• it was generated on-site, andit was generated on-site, and

• is in a suitable containeris in a suitable container

Hazardous Waste IdentificationHazardous Waste Identification

• Satellite collectionSatellite collection• Maximum of 55 gallonsMaximum of 55 gallons• Marked as Hazardous Waste and Marked as Hazardous Waste and

appropriate hazard warning – appropriate hazard warning – flammable, etc. flammable, etc.

• Keep closed at all times when not Keep closed at all times when not actively adding waste to container. A actively adding waste to container. A funnel with a lid is okay as long as lid funnel with a lid is okay as long as lid kept closed.kept closed.

Solvent Waste CollectionSolvent Waste Collection

Hazardous Waste IdentificationHazardous Waste Identification

• Once container is full, the date is entered Once container is full, the date is entered on the label as the Accumulation Start Dateon the label as the Accumulation Start Date

• Container must be removed to the storage Container must be removed to the storage area within 48 hoursarea within 48 hours

• RBP, as a SQG, has 180 days to dispose of RBP, as a SQG, has 180 days to dispose of the waste.the waste.

• The stored waste must be inspected The stored waste must be inspected regularly for damage. Hazardous Waste regularly for damage. Hazardous Waste Drum Inspection Log filled out weekly. Form Drum Inspection Log filled out weekly. Form # 13-7.# 13-7.

Waste TransportWaste Transport

• Transport only by licensed Hazardous Waste HaulerTransport only by licensed Hazardous Waste Hauler• Shipment not accepted without a manifest signed by Shipment not accepted without a manifest signed by

the generator (RBP)the generator (RBP)• Transporter must sign and date manifest Transporter must sign and date manifest

acknowledging acceptance of the waste and give us acknowledging acceptance of the waste and give us a copy of the signed document prior to leaving.a copy of the signed document prior to leaving.

• Manifest must accompany shipment.Manifest must accompany shipment.• Receiving TSD must return signed copy of manifest to Receiving TSD must return signed copy of manifest to

RBP within 30 days acknowledging receipt of waste. RBP within 30 days acknowledging receipt of waste. Not needed if transporter is also the TSD.Not needed if transporter is also the TSD.

Manifest SystemManifest System

• Uniform Hazardous Waste Manifest Uniform Hazardous Waste Manifest infoinfo

• Generator name and addressGenerator name and address

• Generator USEPA ID numberGenerator USEPA ID number

• Manifest Document numberManifest Document number

• Transporter nameTransporter name

• TSD name and addressTSD name and address

Manifest info continuedManifest info continued

• US DOT description of wastes including US DOT description of wastes including Hazardous Waste ID numbersHazardous Waste ID numbers

• Number of containers, total quantityNumber of containers, total quantity

• Emergency contacts Emergency contacts

• Special handling, PPE, etc.Special handling, PPE, etc.

• Signed by RBP representative + titleSigned by RBP representative + title

• Signed by Truck DriverSigned by Truck Driver

• DateDate

EPA Hazardous Waste ID EPA Hazardous Waste ID NumbersNumbers

• 40CFR261 Identification and listing of 40CFR261 Identification and listing of hazardous wastehazardous waste

• D001 is code for our ignitable solvent D001 is code for our ignitable solvent wastewaste

Universal WasteUniversal Waste

• Computer CRTsComputer CRTs• Fluorescent light bulbs – if broken Fluorescent light bulbs – if broken

becomes a hazardous waste.becomes a hazardous waste.• ThermostatsThermostats• PesticidesPesticides• BatteriesBatteries• A SQG not required to notify EPA of A SQG not required to notify EPA of

handling activitieshandling activities

Universal WastesUniversal Wastes

• Label as Universal Waste –Lamp(s)Label as Universal Waste –Lamp(s)

• Universal Waste – Pesticide(s)Universal Waste – Pesticide(s)

• Etc. Etc.

Waste MinimizationWaste Minimization

• RBP signature on Manifest RBP signature on Manifest automatically commits us to having a automatically commits us to having a waste minimization programwaste minimization program

• Minimize waste by:Minimize waste by:• Using out-of-spec product in blend-off Using out-of-spec product in blend-off

programprogram• Finding alternate users of Finding alternate users of

off-spec/obsolete product or raw off-spec/obsolete product or raw materialsmaterials

Alternate Users mustAlternate Users must

• Use 100% of what he takes from usUse 100% of what he takes from us

• Provide a written agreement signed Provide a written agreement signed by a representative of that companyby a representative of that company

• Use the manifest system to receive itUse the manifest system to receive it

• Example is use of our solvent waste Example is use of our solvent waste for fuel value in kilnsfor fuel value in kilns

Emergency response to a Emergency response to a spillspill• Follow our Safety plan proceduresFollow our Safety plan procedures• Save the peopleSave the people• Save the EnvironmentSave the Environment• Save the moneySave the money• The first thing to do is recognize the hazard, alert The first thing to do is recognize the hazard, alert

supervisor, contain the spill if safe to do so.supervisor, contain the spill if safe to do so.• Use PA system to alert employees of danger Use PA system to alert employees of danger

and/or need for any evacuation.and/or need for any evacuation.• If spill can’t be handled internally, notify If spill can’t be handled internally, notify

authorized respondents ( AAA Environmental authorized respondents ( AAA Environmental Industries, WA Fire department, etc.) See Industries, WA Fire department, etc.) See Contingency Plan.Contingency Plan.

Handling SpillsHandling Spills

• Containment procedures including Containment procedures including use of proper PPEuse of proper PPE

• Use and recovery of sorbent Use and recovery of sorbent materials-use minimum neededmaterials-use minimum needed

• Neutralize acid and alkaline spillsNeutralize acid and alkaline spills• Minimize dilution of solvent spillsMinimize dilution of solvent spills• Proper handling and containerization Proper handling and containerization

of hazardous wastes.of hazardous wastes.

Spill Kits at Chem#1 Spill Kits at Chem#1 EntranceEntrance

Spill Kit Pillows- Shipping Spill Kit Pillows- Shipping DeptDept