A premier aerospace and defense company Hazardous Waste€¦ · A premier aerospace and defense company Solid Wastes Discarded Materials 13 Solid Wastes Hazardous Wastes Here is a

1

A premier aerospace and defense company

Hazardous WasteBeing Compliant and helping the Environment

1


Instructor

Patrick Watson, CHMM

ATK Sporting Group

Transportation/Environmental Compliance

12+ years with Clean Harbors

2

y


Duration

Hour and a half

…I COULD take ALL DAY!

3

2


Objective

This basic class will review:

• Waste determination

• Generator/TSDF standards

• Accumulation area requirements

4

Accumulation area requirements

• Satellite accumulation area requirements


The Resource Conservation and Recovery Act

Passed in 1976, phased in over four years

Goal: “To protect human health and the environment”

Identifies hazardous waste

Mandates proper handling, storage, transport and

5

a dates p ope a d g, sto age, t a spo t a ddisposal of hazardous waste

States have the right to administer

• States may be more stringent or broader in scope

• California, Minnesota, Massachusetts, Etc!!!!


Section 1

Hazardous Waste Identification

6

3


Hazardous Waste Determination

Is it a waste?

Is it exempt?

Is it listed?

7

Is it characteristic?

Is it regulated by State?


Discarded Materials

First, these regulations only apply to materials that are being discarded or abandoned.

8


Waste Bull’s-Eye

Discarded Materials

9

Solid Wastes

Hazardous Wastes

Products used for their intended purpose are not being discarded.

4


Solid Waste and Hazardous Waste

For us to understand what hazardous waste is, we must understand the term solid waste.

10


Solid Waste

Statutory Definition:

“Any garbage, refuse, sludge from a wastewater treatment plant, water supply treatment plant, or air pollution control facility, and other discarded

11

pollution control facility, and other discarded material, including solid, liquid, semisolid, or contained gaseous material, resulting from industrial, commercial, mining, and agricultural operations and from community activities.”

AKA, the stuff you are discarding.


Solid Waste

Regulatory Definition:

• Materials that are abandoned;

• Materials that are recycled;

• Materials that are inherently waste-like; and

12

Materials that are inherently waste like; and

• Waste military munitions. Solids

Liquids

Semisolids

Gases

Solid waste does not have to be “solid”

5


Solid Wastes

Discarded Materials

13

Solid Wastes

Hazardous Wastes

Here is a drum of an out dated chemical. It can not be used, thus you want to get rid of it.


Excluded From Being Solid Wastes

Domestic sewage

Industrial wastewater discharge regulated under the Clean Water Act

S t l

14

Scrap metal

Nuclear material regulated under the AEA of 1954

Pulping liquors that are reclaimed

Spent sulfuric acid used to produce virgin sulfuric acid

These are discarded, but are excluded from being solid waste


Excluded From Being Solid Wastes

Discarded Materials

15

Solid Wastes

Hazardous Wastes

Lead scrap is discarded, but is not classified as solid waste since it gets recycled into new lead.

6


Hazardous Waste

Statutory Definition:

“A solid waste, or combination of solid waste, which because of its quantity, concentration, or physical, chemical, or infectious characteristics may (a) cause, or significantly contribute to, an increase in mortality or an increase in serious irreversible, or

16

or an increase in serious irreversible, or incapacitating reversible, illness; or (b) pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, or disposed of, or otherwise managed.”

Bla, bla, blaWake me when it’s over.


Hazardous Waste

In other words, a hazardous waste is a solid waste which is hazardous (to you or the environment).

There are four ways a material can be a hazardous waste.

17

1.Ignitable

2.Corrosive

3.Reactive

4.ToxicWe will look at

each one in just a minute.


Solid Wastes

Discarded Materials

18

Solid Wastes

Hazardous Wastes

Here is a drum of an out dated chemical. It can not be used, thus you want to get rid of it. This chemical is an ignitable liquid.

To be classified as hazardous waste, the solid waste must be:

Ignitable,

Corrosive,

Reactive, or

Toxic

7


Excluded From Being Hazardous Wastes

Household waste

Mining overburden returned to the mine site

Fly ash waste, bottom ash waste, etc.

19

Industrial process wastes which fail the test for TCLP exclusively for trivalent chromium

Cement kiln dust


Excluded From Being Hazardous Wastes

Discarded Materials

20

Solid Wastes

Hazardous Wastes

Household waste collected by the city for safe disposal. This drum contains pool chemicals which are corrosive, but they are specifically excluded.

As you see, hazardous wastes are a subset of solid wastes.


Hazardous Waste Determination

The generator must…

1. Determine if the waste is excluded.

2. Determine if the waste is listed.

3. Determine if the waste is characteristic.

21

4. Finally, determine if the waste is regulated by State.

This can be done by testing or applying knowledge.

(M)SDS

8



How do you sail around the world?

How do you fly?

How do you go to the moon?

How do you classify hazardous waste?

22

o do you c ass y a a dous aste

• This was something completely new.

• EPA was challenged to define hazardous waste, then regulate it.

We’ve already covered exclusions….



EPA decided to go to big industry (sources) to see what wastes they produced.

• Organic chemical manufacturing

• Inorganic chemical manufacturing

• Explosives manufacturing

23

• Pesticide manufacturing

• Petroleum refining

Of all the wastes they produced, EPA decided to regulate the ones that were inherently hazardous.



EPA then decided to examine the major processes (non-specific sources) in the US.

They examined the most common chemicals used in many processes across the US.

• Degreasing operations

24

• Degreasing operations

• Solvents

• Electroplating operations

Again, EPA regulated the hazardous ones.

9



EPA then realized that many chemicals were disposed of because they were kept past there shelf life.

Many unused chemicals were being disposed of because they were outdated.

25

•Acetone

•Benzene

•Chloroform

EPA decided to regulate these virgin (unused) chemicals, off-spec versions, and spills of them.



There are over 5,000,000 known chemicals.

It’s common for a virgin hazardous chemical to not receive a P or U code.

It’s common for a hazardous process waste stream not to receive a K or F code

26

to receive a K or F code.

EPA needed to make a safety net.



EPA then made waste classifications for materials that exhibited a hazardous property.

• Ignitable

• Corrosive

27

• Reactive

• Toxic

These classifications acted as a safety net so hazardous chemicals would not go to non-haz landfill (and into groundwater).

10


Characteristic Hazardous Wastes

D001 Ignitable

D002 Corrosive

D003 Reactive

28

D004- Toxic (Specific)D043


Ignitable – D001

Ignitable, compressed gases

Liquid with flashpoint < 1400F

Solids, other than gases that, may cause fire through friction, absorption of moisture, or

t h i l h

29

spontaneous chemical changes

Oxidizers and organic peroxides


Corrosive – D002

Aqueous solutions with a pH of less than or equal to 2 or greater than or equal to 12.5

Liquids which corrode steel faster than .250 inches per year

30

1 2 3 4 5 6 |7| 8 9 10 11 12 13 14

Acids Neutral Bases

Must contain water!

11


Reactive – D003

Unstable and readily undergo violent change

Can react violently with water

Can form potentially explosive mixtures with water

Readily capable of detonation or explosive decomposition

31

Most 5.2s do not fit the D003 definition.

Generally, only 1.1, 1.2 and 1.3 – not 1.4S


Reactive – D003

• Generates toxic gases, vapors or fumes when mixed with water• Cyanide or sulfide bearing waste that can produce toxic gases

when mixed with pH conditions between 2 and 12.5(Sodium cyanide, potassium cyanide, gold cyanide, lead sulfide, sodium sulfide, silver sulfide)

32

• Capable of explosion if heated under confinement

• DOT Forbidden Explosives


Toxic D004 – D043

Materials that fail T.C.L.P.

Testing shows if hazardous constituent can be leached out of a sample.

If we put this into a non-haz landfill, could it leach

33

harmful substances into our drinking water?

12


Toxic D004 – D043

These are specific metals, pesticides, organic compounds and herbicides.

Only hazardous waste if found at or above the regulatory limit.

34

regulatory limit.

Example: Lead is only a hazardous waste if tests find the level to be 5.0 mg/liter or more.


State Wastes

States can administer their own RCRA Programs, and can be more stringent.

• Minnesota has its own toxicity waste code

• Texas has build your own waste code

35

• Texas has build your own waste code.

• California makes it up as they go along??


Identifying Hazardous Waste

F codes or K codes

D codes State codes

36

P codes or U codes

D codes State codes

13


Identifying Hazardous Waste

F codes or K codes

D codes State codes

Listed Wastes

Characteristic Wastes

37

P codes or U codes

D codes State codes


Manifesting of Hazardous Waste

If a waste receives any listed or characteristic code, the material is deemed a hazardous waste.

RCRA goes on to say hazardous waste must be transported on a hazardous waste manifest.

38

Manifesting of waste is a safetyspecific function (hint hint)


Identify the waste code(s)

Unused drum of Ethyl Acetate

It is past its expiration date, we can’t use it anymore.

We’ve never opened the drum.

39

Unused = virgin = U112

DOT hazard class = 3 = D001

This material is EPA/RCRA hazardous waste with codes U112 and D001.

UN1173, Waste Ethyl Acetate, 3, PGII

14


Copper Electroplating Solution containing copper, lead, potassium cyanide and potassium hydroxide.

Spent Electroplating Waste = F006


40

Spent cyanide = D003 (no P-code, spent!)

Lead = D008

Copper = No Codes

Potassium Hydroxide (pH > 12.5) = D002

RQ, UN1935, WASTE CYANIDE SOLUTIONS, N.O.S., (POTASSIUM CYANIDE, LEAD), 6.1, PG II (D002, D003, D008, F006)



Unused bottle of lead nitrate

Unused lead nitrate = no U or P codes

DOT hazard class = 5 1 = D001

41

DOT hazard class = 5.1 = D001

Material contains lead = D008

This material is hazardous waste with the codes D001 and D008.

UN1469, Waste Lead Nitrate, 5.1(6.1), PGII


Questions

42

15


Section 2

Generation & Accumulation

43


Hazardous Waste Generation

Generator Status

• Determined by weight and type of waste generated

Generator Max. Weight (Codes)

Max. Acute (P-List)

Accumulation Time

Quantity Limit

Large Quantity

> 1000 kg/month

> 1 kg/month

90 days NONE

44

Quantity (LQG)

kg/month kg/month

Small Quantity (SQG)

< 1000 kg/month

< 1 kg/month

180 days < 3000 kg

CESQG < 100 kg/month

< 1 kg/month

NONE < 1000 kg



Registration

• Federal (US Gov):

– CESQG generally doesn’t have to do “anything”

– SQG and LQG must register with EPA and receive an EPA ID#

45

– TSDF must be permitted.

• State:

– Good luck

16



Generator Requirements

• Accumulation time limits

• Start date and “Hazardous Waste” must appear on container

• Ignitable wastes and reactive wastes must be stored at l t 50 f t f t li

46

least 50 feet from property line

• Must always have one person on call or on premises in case of emergency

• Must have emergency information next to phone

• Biennial Reporting Required (Every 2 years)


Hazardous Waste GenerationGenerator Requirements

• Must train all employees with proper waste handling techniques and contingency plan implementation

• Must review training annually

• Facility must have


47

– Internal communication or alarm system

– Telephone or two way radio

– Fire control equipment

– Spill control equipment

– Decontamination equipment

– Water at adequate volume and pressure

Must be tested and maintained!


Hazardous Waste GenerationGenerator Requirements

• Must have aisle space between containers

• Must have prior arrangements with

– Police

Fire department


48

– Fire department

– Local response teams

– Emergency response contractors

– Equipment suppliers

– Hospitals

• Must have contingency plan & Emergency Coordinator!

17


• Treatment, Storage or Disposal Facility (TSDF)

• 1 year onsite storage of waste

• Requirements:

• Obtain/maintain appropriate permits

• Comply with permit requirements


49

Comply with permit requirements

• Ignitable, reactive wastes must be > 50ft from property line (No Smoking Signs)

• Comply with Generator requirements


Hazardous Waste Accumulation Area

TSDF

• Ship < 1 year

Large Quantity Generators

• Ship every 90 days

50

Small Quantity Generators

• Ship every 180 days (or 270)

CESQG

No requirements for shipments


Improper/Inadequate Storage

• Main cause of releases

Store to protect human health/environment


51

18


52



Hazardous Waste Accumulation Area (Primary)

• Secured • Clearly posted “HAZARDOUS WASTE”• Clearly marked boundaries

53

• Impervious surface• Secondary Containment?• Aisle space (what can you see?)• Documented inspections


Secondary Containment

Not a Federal requirement for Gen.

TSDF Requirements

• Impervious Surface


54

Impervious Surface

• Free of cracks & gaps

• Sloped

– Not required if palletized

• Storm water kept out

• Material removed in a timely manner

19


Hazardous Waste Accumulation

Good idea or bad idea?

ABC ChemicalABC Chemical

55

Haz Waste Accumulation Point

Lake, Pond, Stream, Ditch



Haz Waste Accum

Good idea or bad idea?How could it be better?

56

School




Haz Waste Accum

X

Fence w/signage

X

57

“Bermed” Blacktop

X

X

X

XX

X

X

Much Better!


20



Container Selection

• Must be in good condition• Free of cracks or punctures

• Little or no rust

• No leaks

HAZARDOUSWASTE

58

• Compatible with waste

• Capable of being tightly closed

• Must meet UN specifications if being shipped off site


59


60

21


61


62


63

22


64


65


66

23


67


68


69

24


70


71


72

Dupont “Boneyard”Dupont “Boneyard”

25


Container Selection

If container condition is compromised, we must transfer materials or use salvage drum.

Salvage Salvage DrumDrum

OR

73

EPA and DOT require this.

DrumDrum


Container Markings

While accumulating at the generator’s site, a container of hazardous waste must have, at a minimum:

• The words “Hazardous Waste”, and

74

• Accumulation start date

This information is used to warn people and show compliance with the 90day/180day/1 year rule.


Container Markings

Like these…

HAZARDOUSWASTE

75

WASTEACCUMULATIONSTART DATE _______________________________CONTENTS ________________________________

HANDLE WITH CARE!CONTAINS HAZARDOUS OR TOXIC WASTES

26


Container Markings

Some generators apply this marking to the container rather than the minimum. This marking is required when shipping off-

RQ, UN1268 Waste Petroleum Distillates, n.o.s. (Naptha), COMB, PG III

COMB

76

q pp gsite.

000917645FLE 2/1/2010

Federal Cartridge

900 Ehlen Drive

Anoka MN 55303

MND006156590 Ignitable, Toxic

D001, D005

CH309725 Mineral Spirits


Hazardous Waste Marking Requirements

• Hazardous Waste Warning Statement

• Generator's Name and Address

• Generator's EPA Identification Number

• Manifest Document Number

77

• Accumulation Start Date



Isn’t all this a pain?

Isn’t there an easier way to accumulate waste?

78

27


Satellite Accumulation Area (SAA)

… a collection of waste or waste containers at or near the point of generation and under the

79

gcontrol of the generator

“Under the control of the generator” does not mean you have to be standing next to it the entire time.


Managing a Satellite Accumulation Area

UNDER THE CONTROL OF THE OPERATOR:

• Direct visual control…or,

• Documented weekly inspections

80

• Documented weekly inspections


Satellite Accumulation Area (SAA)

Up to 55 gallons for non-acutely hazardous waste

Up to 1 quart for acutely hazardous waste

Must be from a single process

Must be closed unless in use

81

Containers should be in good condition

Containers should be stored in a safe area

No accumulation time limits

When filled, container must be moved to storage area within 72 hours

28


Satellite Accumulation Area

Waste mineral spirits are poured into an

82

paccumulation drum in the Satellite!

When full, we have 3 days to move the drum to the accumulation area.

The 1 year time limit begins when the container limit is reached.


Satellite Accumulation Marking Requirements

• The words “Hazardous Waste” , or

• The name or description of the waste (i.e. “Waste Acetone”)

• Containers must be marked

83

HAZARDOUSWASTE

ACCUMULATIONSTART DATE _______________________________CONTENTS ________________________________

HANDLE WITH CARE!CONTAINS HAZARDOUS OR TOXIC WASTES

Mineral spirits

Mineral spirits 100 D001, D005


Questions

Questions?

84

Documents

A premier aerospace and defense company Hazardous Waste€¦ · A premier aerospace and defense company Solid Wastes Discarded Materials 13 Solid Wastes Hazardous Wastes Here is a