Transcript Accumulation times

Accumulation (Basic)
Mickey Pierce
Hazardous Materials Specialist
Santa Clara County, Dept. of
Environmental Health
The phase of the day is….
TOPICS
1.
2.
3.
Accumulation Times
Waste Counting
(including Episodic
Generation)
The Rules That Apply
Accumulation Times
Accumulation Time
• Monthly amounts are not averages..
• Each month determined on its own
– If Jan-Nov generate small amounts then one
set of rules applies to that waste, BUT…
– If generate lots of waste in Dec with house
cleaning, that waste may face different set of
rules!!
Accumulation Times
22 CCR Section 66262.34 (a)-(d)
• Accumulation time frames depend on
amount of waste generated (monthly and
total), where the waste is headed for disposal
and how it’s accumulated (e.g. satellite area).
LQG, SQG, CESQG
• LQG”: > 1000 kg of hazardous waste
(RCRA and/or non-RCRA) in any month.
• “SQG”: < 1000 kg of hazardous waste
(RCRA and/or non-RCRA) in any month.
• “CESQG”: < 100 kg of hazardous waste
(RCRA and/or non-RCRA) in any month.
• Federal Terms
Accumulation Time- Default
• Accumulation clock starts with first drop
• Can accumulate only 90 days without a “full permit”
issued by DTSC
• Who does this apply to?
– LQGs (generate more than 1000 kg/month)
– People who ignore the SQG/CESQG rules
– > 1 kg Extremely/Acutely Hazardous Waste
Accumulation TimesThe first exception
• Generate < 1000 kg/month (SQG)
– Accumulation clock starts with first drop
• Can accumulate 90 days OR 180 days OR 270
days
• 180 days- must not exceed 6000kg total ever,
have one person onsite during hours, post
emergency information.
• 270 days- same as above & transport >200 miles
• CCR 66262.34(d)
Hazardous Waste Accumulation
< 1000 kg/mo. AND never more than
6,000kg onsite: can accumulate for 180
days
< 1000 kg/mo., AND < 6,000kg onsite
AND transport >200 miles to TSD: can
accumulate for 270 days
Accumulation TimeThe Second Exception
• Generate <100 kg/month (CESQG) or
<1 kg extremely/acutely haz waste
– Accumulation clock starts the day they
reach 100 kg (approximately 27 gallons) of
waste.
• Can accumulate for 90 days* from that point
• CCR 66262.34(b)(1)
ACCUMULATION TIME LIMIT SUMMARY
Satellite Accumulation
• Two parts
– Cannot remain on site more than 1 year
from first drop
OR
– Once full, when 90/180/270 is reached
WHICHEVER COMES FIRST APPLIES!!
– CCR 66262.34(e)(1)
Satellite Accumulation
(The extra special rules that apply)
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At or near the point of generation,
Under control of the generator
Containers only
Mark container w/ initial date of accumulation
No more than 55 gallons or 1 quart of acutely or
extremely hazardous waste per process (may
use separate containers subject to your
approval)
• Move to “90-day” accumulation area within 3
days of reaching 55 gallons.
– Mark label with THIS DATE TOO!!!
S.A., in the lab
• Different rule for laboratories
– Do not have to be “at or near the point of generation”,
but rather “as close as practical”
– Not required to “under the control of the operator” but
rather “managed by designated personnel”
– “designated personnel” must be trained on rules
• Details are in HSC 25200.3.1
Why Worry About Amount Of
Hazardous Waste Generated?
• Different accumulation times for SQGs
and CESQGs
• CESQGs and SQGs may also use relaxed
contingency plan and training plan
requirements
• CESQGs and SQGs that generate certain
wastestreams may use the consolidated
manifest.
So, what happens when…
• You see a 55-gallon drum that is ¼ full that the person
says has been there for 2 years, and it’s the only waste
they generate?
• You see a drum that is “satellite accumulation” that has
been moved from the SAA three months ago, and was
re-labeled with the moved date?
• A lab uses satellite accumulation (5-gallon bucket) in a
room, but then consolidates the buckets in a drum on the
back pad?
• You come across that one man auto repair shop with 1
oil drum, 1 antifreeze drum, 1 filters drum, and 1
absorbent bucket in the entire shop?
Waste Counting
WASTE COUNTING
• Do you count all wastes generated in all
cases? No
• At no time are excluded recyclable materials
(i.e. reused onsite as a replacement for a
commercial product in manufacturing) counted
as waste
• Silver, that once recovered from photoprocessing solutions is being sent for
reclamation, is never counted. (spent fixer
containing the silver is IF silver not to be
reclaimed onsite)
WASTE COUNTING
• For the purposes of determining LQG,
SQG or CESQG status relating to
accumulation times, all other wastes are
counted.
• This includes wastes that are generated
and then treated onsite under a Tiered
Permitting authorization.
What is “Episodic Generation”?
• Just like the name implies:
– An occasional act at which time more than
normal waste is generated, and that “extra”
waste generation pushes the business from
one category (SQG) to another (LQG)
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Lab clean-out at end of school year
Tank cleaning
Sludge removal from wash pit
Asbestos removal project
EPISODIC GENERATION
• If a business is normally a SQG but occasionally
generates enough waste to be a LQG, how long
does that site have to comply with LQG rules?
• RCRA Orientation Manual” which says “If a
generator’s status does in fact change, the
generator is required to comply with the
respective regulatory requirements for that class
of generators for the waste generated in that
particular month.”
EPISODIC GENERATION
• If a business is subject to LQG standards
because of episodic generation, are they then
required to provide a tank assessment for tanks
unrelated to the activity that caused them to be a
LQG?
• Episodic LQG events should not trigger the full
spectrum of LQG standards on a generator.
This answer is grounded in the spirit of the rule
which is to regulate LQGs at a higher standard
because of the higher potential impact if there is
a release.
The pesky little rules
Rules for everyone
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Labeling
Accumulation time limits
Container management
Manifests
– Consolidated manifests
• EPA ID Number
• Training
Rules for <1000 kg
• Title 22 refers you to the federal rule, 40 CFR,
section 262.34 (d-f)
• Container management
– Open, good condition, not incompatible, inspected
(but no written logs required)
• Tank management
– Special rules in 40 CFR 265.201
• Labeling and accumulation times
More <1000 kg rules
• LDRs
• Preparedness and Prevention
– Emergency equipment (relevant to wastes onsite),
communications (including phone),
– Testing/maintenance of emergency equipment
– Aisle space for access in emergency
– Maintained to minimize releases
• Emergency Info Posting
– Emerg. Coordinator (name & #),
location of spill equip., 911/FD #
Documents for LQGs
• Manifests/Bill of
Lading/
Consolidated
Manifest
Documentation
• LDRs
• Inspections (Logs)
• Waste
Determination
• Contingency Plan
• Training Plan
• Training records
• Biennial Reports
• SB 14/Waste Min
plans and reports
• Recyclable
Materials Report
(UPCF)
• Tank/Secondary
containment
Assessment
Manifests
• New manifests in use as of Sept, 2006
– Generator still needs to submit a copy to
DTSC (but no more Blue, you have to ask)
• Photocopy or send original once TSDF copy
received
– Keep TSDF copy for 3 years
– Exception reports if no TSDF copy received
• 45 days for LQG, 60 days for SQG/CESQG
LDRs
• General rule:
– If it’s a Federally regulated waste, it should have
a LDR
• May file one LDR per wastestream at
beginning of each year to cover all
shipments IF
– Wastestream does not change
– TSDF does not change
Inspections
• Tanks (DAILY)- Keep written logs
– Looking for corrosion, releases, working
condition, overflow, spill control and monitoring
equipment
• Containers (WEEKLY)- No logs required
– Look for labels, condition, spills
• All containment should be examined too for
both containers and tanks
Waste Determination
• Make sure that there is one for each
potential waste
– Generator knowledge can be used in place of
analytical testing
• Can ask for some type of demonstration or
documentation of the basis of this determination
• Is the generator’s responsibility, not yours
– If you don’t like it or believe it, sample it
Contingency Plan
• Above all else- should be useful info
• Items required are generally required also
as part of Business Plan (Emergency
Plan)
• SQGs and CESQGs have special rules*
Contingency Plan
• Should include:
– Evacuation routes
– OES phone # (1-800-852-7250)
– How to respond to a fire, explosions, releases
– Agreements with emergency responders
– Name, address, phone # of emergency
contact
• Including both home and work
– Emergency equipment list and location
Training (66265.16)
• Program should be directed by a person trained
in hazardous waste management
• Program needs to be designed to ensure that
facility personnel are able to respond effectively
to emergencies by familiarization to emergency
procedures (including the contingency plan),
emergency equipment & emergency systems.
• Plan needs to be relevant to the positions in
which they are employed
Training
Training should:
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Be tailored to each job description
Be “adequate” for job performance
Cover hazards, handling, emergency
procedures
• Training plan
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New hire: within 6 months
No unsupervised work until trained
Annual refresher
• Training records
Training Plan and Records
• Three part program
• Different rules for CESQGs and SQGs*
• Plan--Includes some parts, should be
taught by a person trained in hazardous
waste management procedures
– Job title and duties
– Employee name
– Types of training for that tile
Training Plan- New Staff
• New staff must get the following within 6
months of being hired or re-assigned:
– How to respond to emergencies
– Locations of equipment
– Communications/alarms
– Shutdown/automatic cut/off
– Response to fire/explosion
• NO unsupervised work prior to this!!
Training Plan- On-going
• At a minimum, orientation topics should
be covered again.
• Documentation should be kept (logs
with topic, date and attendee signature
are easy) until 3 years after employee
leaves.
• BE CREATIVE- give business ideas on
how to do this effectively
SQG and CESQG rules
• Contingency Plan
– Only need to post emergency number
(911), name of coordinator and location of
emergency equipment next to the phone
• Training Plan
– No written plan required.. Employees are
supposed to be familiar with their roles in
an emergency (at a minimum).
Biennial Reports
• Only required if >1000 kg RCRA waste
generated in any month of a year.
• Business should prepare and submit to
DTSC on March 1, even numbered
years
• Really a report of:
– type of wastes sent offsite by code
– Efforts/changes made to reduce volume
and/or toxicity
– calendar years covered
SB14/Waste Minimization
• Formal plan and report regarding waste
minimization
• For generators of >12,000 kg/year
– Does not include such wastes as used oil,
automotive fluids, universal waste
• Plan should be done every 4 years
SB14/Waste Minimization
• Plans should include:
– Waste stream specifics (what, how, how
much)
– Potentially Viable alternatives
• Including administrative and inventory changes
– Consideration of each alternative
• Can include economic feasibility
– Rationale for choices
– Timetable for making any changes noted
Recyclable Materials Report
• For businesses that recycle over 100 kg of
waste in any month ONSITE
• Use the UPCF forms
• Report notes
– general description of the recycled material
– process using the material
– basis for claiming exemption
– constituents of the material
Special Rules for “special” wastes
• Filters (Oil and Fuel)
– Drained of free flowing liquid
– Mark/label only “drained used oil filters” or
“used oil and gasoline filters” and start date
– Hold for up to 1 year (for < 1 ton-- ≈ 2 drums
of crushed), 180 days if > 1 ton)
– Closed (but not sealed/ring locked until
transport)
– Keep records (bill of lading/consol man) 3 yrs
Contaminated Containers
• AKA “Empty” Containers
• No “steady stream” if held in any
orientation
• Mark with date emptied, move within 1 yr.
• Not a HW if empty and:
– Reclaimed for scrap value
– Recondition or remanufacture
– Ship to intermediate prior to either of above
Contaminated Containers
• Once empty, 5 gallons or less in size may
go to trash
• Does NOT include
– Contaminated absorptive materials
(cardboard, wood)
– Aerosol cans
– Gas cylinders (at or near atmospheric press.)
– Containers to be sent for refill by supplier
Lead Acid Batteries
• Accumulate up to 1 ton (≈60 batteries) for
up to 1 year
– >1 ton, 180 days
• No marking, except for damaged batteries
• Keep records fo removal for 3 years
• Move damaged batteries to secure
container
Rags
• Best bet: send to commercial laundry
(must be authorized to take them, not your
corner dry cleaner or take home!!)
• Can not use for spill clean up
• No free liquids in rag (non-saturated)
• IF not commercially laundered, subject to
all HW rules (IF you find them to be HW)
– Includes wipes!!
How to Get Help!
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Your CUPA liaison
DTSC Fact sheets – www.dtsc.ca.gov/publications
State Regulations: www.calregs.com
State Statute: www.leginfo.ca.gov
DTSC Public & Business Liaisons
(800) 72TOXIC (1-800-728-6942)
• HW Manifest Training:
http://www.dtsc.ca.gov/IDManifest/Manifests.cfm#Manifest_Regulation_Training
• CalCUPA www.calcupa.net