Transcript Annual RCRA Hazardous Waste Training Program

Annual RCRA Hazardous
Waste Training Program
CFR 40
• EPA has implemented:
• Regulations for Identification of wastes
• Performance standards for generators
• Hazardous waste facility permit program
• Mandated annual training for employees
who handle, process or may regularly be
exposed to hazardous waste
Training Objectives
• Understand types of waste generators
• Define hazardous wastes
• Describe proper handling and storage of
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hazardous waste
Select proper waste containers
Label and mark waste containers
Discuss truck loading requirements
Complete paperwork for waste shipment
Response to emergencies
Types of Generators
• Large quantity –generates >1000kg(2205
lbs) in any month
• Small quantity - generates <1000kg(2205
lbs) in any calendar month (approx 5
drums)
Never accumulates >6000kg on site
* Very small quantity – generates < 100kg
per month; never >1000kg on site
SQG Must
• Obtain a USEPA identification number
• Identify Hazardous wastes
• Keep records of wastes
• Inspect waste containers regularly for
damage; document these inspections
• Dispose of waste through licensed waste
haulers/facilities
• Fill-out and retain proper shipping papers
What is a hazardous waste?
• A solid waste, or combination of solid wastes,
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which because of its quantity, concentration, or
physical, chemical, or infectious characteristics
may:
Cause or significantly contribute to an increase
in mortality or an increase in serious irreversible,
or incapacitating reversible illness; or
Pose a substantial present or potential hazard to
human health or the environment when
improperly treated, stored, transported,
disposed of, or otherwise managed.
What is a hazardous waste? Contd
• Listed Wastes – automatically hazardous if it is
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named on RCRA list (>400 chemicals)
Characteristic Waste- waste is
Ignitable – easily combustible/flammable
Corrosive - pH 2.0 or less;12.5 or more
Reactive – unstable or reacts violently with
water or other materials
Toxic – if extract has heavy metals, pesticides
What is a Hazardous Waste? contd
• Acutely Hazardous wastes- these are so
hazardous (primarily some pesticides or
dioxin-containing wastes) that generation
of 2.2 lbs or having that much on-site
would be enough to categorize a company
as a Large quantity generator
RBP waste
• RBP is a small quantity generator
• Primary hazardous waste is solvent from tank
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washout. This is collected at a site other than
the storage site. Suitable container for
flammable liquid is a steel drum.
Satellite – waste drum collection in Chem Mix#1
area; maximum 55 gals
Storage- Flammable Storage Room
Ignitable Wastes
• Code D001 if:
• A liquid with flash point <140F; exception
is an aqueous solution with <24% alcohol
• A non-liquid capable at 77F and 760mm
pressure of causing fire due to friction,
absorption of water or spontaneous
reaction and, if ignited, burns vigorously
Ignitable Wastes continued
• It is an oxidizer, such as chlorate,
permanganate, inorganic peroxide, or a
nitrate that yields oxygen to stimulate
combustion of organic material
RBP Waste
• Corrosive wastes – unusable raw materials
and/or rejected/obsolete products that
cannot be utilized. Suitable containers are
those not damaged by corrosive nature of
waste.
• Storage- return area
• A waste is not a waste until RBP makes
the determination that we cannot use it.
Corrosive Wastes NR
• EPA waste code D002
• Classed as corrosive waste if:
• Aqueous solution wiyh pH<2 or >12.5, or
• Liquid that corrodes plain carbon steel
with carbon content of 0.20% at rate
>6.35mm/0.25” year at 55C.
Reactive Waste If
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• Reacts violently with water, or
• Forms potentially explosive mixtures with
water, or
• Normally unstable and readily undergoes
violent change without detonating, or
• When mixed with water generates toxic
gases sufficient to be danger to humans
Reactive Waste continued
• If a cyanide which when exposed to pH
between 2-12.5 can generate toxic gases.
• example would be the cyanide locked in
cabinet in Brad’s area. If we decided we
couldn’t use it or find a user this would be
disposed of under this hazardous waste
code
Toxic Wastes
• EPA waste codes D004-D043
• Specific test method used to determine
level of listed hazardous material.
Examples are mercury, chromium, lead,
pesticides, benzene
Waste Treatment
• RBP has no permit as a waste treatment
facility
• Elementary neutralization of a waste
whose only hazard is pH based is allowed
as long as:
• it was generated on-site, and
• is in a suitable container
Hazardous Waste Identification
• Satellite collection
• Maximum of 55 gallons
• Marked as Hazardous Waste and
appropriate hazard warning – flammable,
etc.
• Keep closed at all times when not actively
adding waste to container. A funnel with a
lid is okay as long as lid kept closed.
Solvent Waste Collection
Hazardous Waste Identification
• Once container is full, the date is entered on the
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label as the Accumulation Start Date
Container must be removed to the storage area
within 48 hours
RBP, as a SQG, has 180 days to dispose of the
waste.
The stored waste must be inspected regularly
for damage. Hazardous Waste Drum Inspection
Log filled out weekly. Form # 13-7.
Waste Transport
• Transport only by licensed Hazardous Waste Hauler
• Shipment not accepted without a manifest signed by the
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generator (RBP)
Transporter must sign and date manifest acknowledging
acceptance of the waste and give us a copy of the
signed document prior to leaving.
Manifest must accompany shipment.
Receiving TSD must return signed copy of manifest to
RBP within 30 days acknowledging receipt of waste. Not
needed if transporter is also the TSD.
Manifest System
• Uniform Hazardous Waste Manifest info
• Generator name and address
• Generator USEPA ID number
• Manifest Document number
• Transporter name
• TSD name and address
Manifest info continued
• US DOT description of wastes including
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Hazardous Waste ID numbers
Number of containers, total quantity
Emergency contacts
Special handling, PPE, etc.
Signed by RBP representative + title
Signed by Truck Driver
Date
EPA Hazardous Waste ID Numbers
• 40CFR261 Identification and listing of
hazardous waste
• D001 is code for our ignitable solvent
waste
Universal Waste
• Computer CRTs
• Fluorescent light bulbs – if broken
becomes a hazardous waste.
• Thermostats
• Pesticides
• Batteries
• A SQG not required to notify EPA of
handling activities
Universal Wastes
• Label as Universal Waste –Lamp(s)
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Universal Waste – Pesticide(s)
• Etc.
Waste Minimization
• RBP signature on Manifest automatically
commits us to having a waste
minimization program
• Minimize waste by:
• Using out-of-spec product in blend-off
program
• Finding alternate users of offspec/obsolete product or raw materials
Alternate Users must
• Use 100% of what he takes from us
• Provide a written agreement signed by a
representative of that company
• Use the manifest system to receive it
• Example is use of our solvent waste for
fuel value in kilns
Emergency response to a spill
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Follow our Safety plan procedures
Save the people
Save the Environment
Save the money
The first thing to do is recognize the hazard, alert
supervisor, contain the spill if safe to do so.
• Use PA system to alert employees of danger and/or need
for any evacuation.
• If spill can’t be handled internally, notify authorized
respondents ( AAA Environmental Industries, WA Fire
department, etc.) See Contingency Plan.
Handling Spills
• Containment procedures including use of
proper PPE
• Use and recovery of sorbent materials-use
minimum needed
• Neutralize acid and alkaline spills
• Minimize dilution of solvent spills
• Proper handling and containerization of
hazardous wastes.
Spill Kits at Chem#1 Entrance
Spill Kit Pillows- Shipping Dept