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Hazardous Waste Generator Standards For LQGs

What makes a facility an LQG?

•

Large Quantity Generator

– Generates • > 1000 kg/mo (~5 drums), • > 1kg P waste – OR – Accumulates • > 6000 kg waste or • 1 kg P waste

40 CFR 262 Subpart A – General Standards

• Perform a hazardous waste determination pursuant to 40 CFR 262.11

• Notify the DEP and obtain an EPA/DEP identification number pursuant to 40 CFR 262.12. Notification forms are available on DEP’s website: http://www.dep.state.fl.us/waste/quick_topics/forms /pages/62-730.htm

Haz Waste in the Trash

LQG Improperly Managing Waste

Haz Waste in the Trash

LQG Properly Managing Waste

40 CFR 262 Subpart C – Accumulation Requirements

• 262.34

Accumulation Standards – Hazardous waste may be accumulated in containers if the requirements of 40 CFR 265 Subpart I are met – Hazardous waste may be accumulated in tanks if the requirements of 40 CFR 265 Subpart J are met – P.E. certified containment buildings meeting the requirements of 40 CFR 265 Subpart DD may be used

LQG - Accumulation Limits

• LQGs may accumulate waste for 90 days – N/A in satellite accumulation areas under 262.34(c) • A one time 30-day extension may be granted by the DEP under unusual circumstances

Satellite Accumulation

• 55-gallons • At or near the Point of Generation • Labeled “Hazardous Waste” or other Words that Describe Contents • Mark waste accumulated in excess of 55 gallons with the date of accumulation • 72 hours to move to storage area – Or begin managing the satellite area in full compliance with pre transport standards

LQG - Satellite Container

LQG - Satellite Container

LQG - Satellite Container

LQG - Satellite Container

Containers Over 55 gallons

LQG – SAP

LQG – SAP

Weekly Container Inspections

• Weekly Container inspections [40 CFR 265.174] • Container Inspection Records [62-730.160(6), FAC] – Date – Time – Legibly written name of the inspector – Number of containers – Condition of containers – Notes of observations made, date and nature of repairs or corrective actions – Keep 3 years

Weekly Container Inspections

LQG Containers – Dates/Labels

• Marked with date of accumulation

LQG – Container Condition

LQG – Container Condition

LQG - Container Compatibility

LQG - Closed Container

LQG – Closed Container?

LQG – Closed Container

LQG – Closed Container

LQG – Closed Container/ Subpart CC Requirements

LQG – Container Management

LQG 50’ Setback

• 50 foot setback from property boundary for ignitable or reactive waste for LQGs

General Aisle Space

• 265.35

• Access to emergency equipment must also be preserved, including fire control, spill control and decontamination equipment

40 CFR 262 Subpart C – Pre Transport Requirements

• 262.30

Packaging • 262.31 Labeling • 262.32

Marking • 262.33

Placarding – Sections adopt USDOT Hazmat rules by reference

LQG - Containers - Aisle Space

LQG - Containers – Aisle Space/Inspections

LQG - Containers - Aisle Space/Inspections

LQG Accumulation Area

LQG Accumulation Area

LQG Accumulation Area

LQG - Tanks

• Label “Hazardous Waste” • Document 90 day storage limit compliance • Comply with 40 CFR 265 Subpart J standards – P. E. Certification – Secondary containment – Daily inspections

LQG - Tanks

LQG - Maintenance and Operation

LQG - Maintenance and Operation

LQG - Maintenance and Operation

LQG - Maintenance and Operation

LQG – Proper Maintenance and Operation

40 CFR 262 Subpart A – Ensure Proper Disposal

• Waste must be transported, treated or disposed of at facilities that have an EPA ID # • Generators shipping waste off site must use a hazardous waste manifest – May not use tolling agreement instead of manifest – May have to register with PHMSA as a Hazmat Shipper • The generator must designate a receiving facility on the manifest that is permitted to treat, store or dispose of the shipped waste

LQG Waste Minimization Certification

• 262.27

Waste Minimization Certification (a) “I am a large quantity generator. I have a program in place to reduce the volume and toxicity of waste to the degree…”

40 CFR 262 Subpart B – The Manifest

• 262.20

General Requirements • 262.21

Manifesting Tracking/Printing and Obtaining Manifests • 262.22

Number of Copies • 262.23

Use of the Manifest

40 CFR 262 Subpart B – The Manifest

• 262.22

Number of Copies • Provide a copy for: – The generator – Each transporter – TSDF – Return copy for generator

40 CFR 262 Subpart B – The Manifest

40 CFR 268 - Land Disposal Restrictions

• LDR Notification • LDR Certification • Retain Documentation for 3 years (forever?) • Waste Analysis Plan

LDR Notice Contents

• All Applicable Waste Codes • Treatability Group • Constituents subject to regulation, if not all regulated constituents – Underlying Hazardous Constituents, if applicable • Manifest Document Number of Shipment • Waste analysis data where available

40 CFR 262 Subpart D Recordkeeping and Reporting

• Copies of Hazardous Waste Determinations and Analyses • Manifests • Exception Reports • Biennial Reports for LQGs • Incident Reports re: Spills or Emergencies Requiring • Implementation of the Contingency Plan (did you notify the DEP within 15 Days?) • Documentation from Clean up after spills or other emergencies • Maintain Documents for 3 years (forever?)

Training

• Do facility personnel complete hazardous waste training?

• Is the trainer must be adequately trained in hazardous waste management procedures • Does the training cover safety?

• Does the training cover emergency response procedures, including equipment handling and inspection?

Training

• Does the training cover hazardous waste identification and handling procedures?

• Does the facility maintain job titles and job descriptions for employees managing hazardous waste?

• Do the job descriptions include the requisite skills, education and experience?

• Do the job descriptions include a list of the person’s duties?

Training

• Do employees complete initial training within 6 months of hiring or assignment of HW management responsibility? • Do they work unsupervised until training is complete?

• Is the training reviewed annually?

• Are all required training records kept at the facility? Until closure/3 years?

40 CFR 262 Subpart C – Personnel Training

Proper Training?

Proper Training?

40 CFR 265 Subpart C – Preparedness and Prevention

• Maintenance and Operation – 40 CFR 265.31

• Minimize the possibility of fire, explosion, or release of hazardous waste or hazardous waste constituents to the air, soil, surface, or groundwater

40 CFR 265 Subpart C – Required Equipment

• Internal communications or alarm equipment [40 CFR 265.32(a)] • Telephone or two-way radio [40 CFR 265.32(b)] • Spill control/decon equipment [40 CFR 265.32(c)] • Fire Equipment [40 CFR 265.32(c)] – Water or foam available at adequate volume or pressure [40 CFR 265.32(d)]

Aisle Space Extends to Emergency Equipment

40 CFR 265 Subpart C – Required Equipment (cont.)

40 CFR 265 Subpart C – Required Equipment (cont.)

40 CFR 265 Subpart C – Required Equipment (cont.)

40 CFR 265 Contingency Plan

40 CFR 265 - Contingency Plan Contents

•

Must be accessible in an emergency

• Fire, Spill, Explosion Response Procedures • A description of arrangements with local authorities • Emergency Coordinator’s name(s), address(es) and telephone numbers • Emergency equipment list • Specifications and capabilities of emergency equipment • Facility diagrams and maps • Locations of emergency equipment • An evacuation plan and routes • Evacuation/alarm signals

40 CFR 262 Subpart C – Emergency Coordinator

• 40 CFR 265.55

o Have at least one designated coordinator o o Coordinates all emergency response measures Either on premise or short distance away o Familiar with all aspects of contingency plan, wastes handled, and location of records o Has the authority to commit resources

40 CFR 265 Subpart C – Emergency Arrangements

• Questions?