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9 th Annual California Unified Program Conference. Advanced Hazardous Waste Inspector Training. Evaluations. The are two evaluations one for the overall conference and one for this course, please complete them.

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9 th annual california unified program conference
9th Annual California Unified Program Conference

Advanced

Hazardous Waste

Inspector

Training

9th Annual California Unified Program Conference


Evaluations
Evaluations

  • The are two evaluations one for the overall conference and one for this course, please complete them.

  • We modify the hazardous waste track based on your input. Would you like more of this? or other topics,

    • LDRs

    • Closure costs

    • Advanced Waste classification

    • Waste counting

  • This course and the conference is modified in response to your comments/requests.

9th Annual California Unified Program Conference


John misleh michael vizzier

John Misleh &Michael Vizzier

San Diego County CUPA

[email protected]

[email protected]

9th Annual California Unified Program Conference


Objective
Objective

  • Use US EPA Office of Solid Waste (OSW) and DTSC guidance documents to analyze advanced issues.

  • Examine scenarios and discuss varying interpretations.

  • Three topic areas:

    • Part I: Point of generation

    • Part II: Waste Analysis

    • Part III: Is it a Container or is it a Tank?

  • We’ll start with the laws and regulations then progress through guidance documents and scenarios.

9th Annual California Unified Program Conference


Part i point of generation

Part I,Point of Generation

Is it Waste?

Is it a Hazardous Waste?

9th Annual California Unified Program Conference


Is it a waste 66261 2 definition of waste
Is it a Waste?§66261.2. Definition of Waste

  • §66261.2(a) "Waste" means any discarded material of any form (liquid, semi-solid, solid or gaseous) that is not excluded by §66261.4(a) or §66261.4(e) or that is not excluded by H&SC §25143.2(b) or H&SC§ 25143.2(d).

  • (b) A discarded material is

    • (1) relinquished, or

    • (2) recycled, or

    • (3) considered inherently waste-like.

  • Of course there are other exceptions…

9th Annual California Unified Program Conference


Is it a hazardous waste 66261 3 definition of hazardous waste
Is it a Hazardous Waste?§66261.3. Definition of Hazardous Waste

  • §66261.3 (a) A waste as defined in §66261.2 is a hazardous waste if:

    • (1) it is not excluded from classification as a waste or a hazardous waste under H&SC §25143.2(b) or §25143.2(d) or §66261.4; and

    • (2) it meets any of the following criteria:

      • (A) it exhibits any of the characteristics of hazardous waste identified in article 3

      • (B) it is listed in article 4

9th Annual California Unified Program Conference


A hazardous waste is
A Hazardous Waste is:

  • Declared – Generator decides to manage as a hazardous waste

  • Characteristic – A representative sample exhibits a hazardous characteristic (RCRA D001 to D043 + California corrosive, reactive, & toxic) (22 CCR, Ch. 11, Art. 3)

  • Listed (22 CCR, Ch. 11, Art. 4)

    • F listed (Non-Specific Sources)

    • K listed (Specific Sources)

    • P Listed (Acutely Hazardous Off-Spec, Spills)

    • U listed (Hazardous Off-spec, Spills)

    • M listed (Ch. 11, Art. 4,1 mercury containing products)

  • Mixtures of solid & hazardous waste

  • Residues derived from a hazardous waste

9th Annual California Unified Program Conference


Example of waste listed as hazardous due to benzene
Example of waste listed as hazardous due to Benzene

  • D018 – Benzene concentration  0.5 mg/l TCLP

  • F037 – Petroleum refinery primary separation sludge

  • F038 – Petroleum refinery secondary separation sludge

  • K085 – Distillation bottoms from the production of chlorobenzenes

  • P028 – Benzene, (chloromethyl)- (commercial chemical product)

  • U019 – Benzene (commercial chemical product)

9th Annual California Unified Program Conference


Mixture rule
Mixture Rule

  • A mixture of a solid waste & a characteristic (Art. 3 or Subpart C) hazardous waste is hazardous only if the resulting mixture exhibits a hazardous characteristic.

  • A mixture of a solid waste & a listed (Art. 4 or Subpart D) hazardous waste that is listed only for ignitability, corrosivity or reactivity (I,C,R) is hazardous only if the resulting mixture exhibits a hazardous characteristic.

  • A mixture of a solid waste & a listed (Art. 4 or Subpart D) hazardous waste that is listed only for toxicity remain listed as a hazardous waste.

9th Annual California Unified Program Conference


Derived from rule treatment residue
Derived from Rule(Treatment Residue)

  • Residues from treating, storing or disposing a characteristic waste are hazardous only if they exhibit a characteristic of hazardous waste.

  • Residues from treating, storing or disposing a listed waste, that is listed solely for ignitability, corrosive or reactive (I,C,R), are hazardous only if they exhibit a characteristic of hazardous waste.

  • Residues from treating, storing or disposing a listed waste, which is listed for toxicity, remain a listed hazardous waste.

9th Annual California Unified Program Conference


Who makes a waste determination

Who Makes a Waste Determination?

The

Generator

9th Annual California Unified Program Conference


What s a generator 66260 10
What’s A Generator? §66260.10

  • Generator: "any person, by site, whose act or process produces hazardous waste identified or listed in Chapter 11 or whose act first causes a hazardous waste to become subject to regulation.”

9th Annual California Unified Program Conference


What s a person 66260 10
What’s A Person? §66260.10

  • Person: "an individual, trust, firm, joint stock company, federal agency, corporation (including a government corporation), partnership, association, state, municipality, commission, political subdivision of a state, or any interstate body. “Person" also includes any city, county, district, commission, the State or any department, agency or political subdivision thereof, any interstate body, and the Federal Government or any department or agency thereof to the extent permitted by law."

9th Annual California Unified Program Conference


What s a site 66260 10
What’s A Site? §66260.10

  • The term, "by site," refers to where a hazardous waste is generated. The regulations do not explicitly define the term “site.” But the regulations do define onsite.

  • "Onsite" means the same or geographically contiguous property which may be divided by public or private right-of-way, provided the entrance and exit between the properties is at a crossroads intersection, and access is by crossing as opposed to going along, the right-of-way. Noncontiguous properties owned by the same person but connected by a right-of-way which that person controls and to which the public does not have access, is also considered onsite property.

9th Annual California Unified Program Conference


Whose act or process
Whose Act or Process?

  • A generator is defined as the person whose act or process first causes a hazardous waste to become subject to regulation.

    • Sometimes the generator of a waste may not necessarily be the person who actually produced the waste. For example, if a cleaning service removes residues from a product storage tank excluded under §261.4(c), the person removing the residues is the first person to cause the waste to become subject to regulation, not the owner of the tank.

    • In case the cleaning service and the owner are co-generators.

9th Annual California Unified Program Conference


Co generators
Co-Generators

  • The person removing the waste from the unit is not the owner or operator of the unit, but may be considered a generator. The owner or operator of the unit may also be considered a generator since the act of operating the unit led to the generation of the hazardous waste. In other words, both the remover of the waste and the owner or operator of the tank are considered to be co-generators.

  • In cases where one or more persons meet the definition of generator, all persons are jointly and severally liable for compliance with the generator regulations. The parties may through a mutual decision have one party assume the duties of generator, but in the event that a violation occurs, all persons meeting the definition of generator could be held liable for the improper management of the waste (45 FR 72026; October 30, 1980).

9th Annual California Unified Program Conference


Point of generation
Point of Generation

  • The point where a material becomes a waste is also the point where:

    • Waste determination is made; samples are taken.

    • Treatment tier determination is made

    • Container & tank standards are required

    • RCRA Land Disposal Restrictions apply

9th Annual California Unified Program Conference


Point of waste origination defined per 22 ccr 66260 10
Point of Waste OriginationDefined per 22 CCR §66260.10

  • "Point of waste origination" (22 CCR) means as follows:

    • (1) When the facility owner or operator is the generator of the hazardous waste, the point of waste origination means the point where a solid waste produced by a system, process, or waste management unit is determined to be a hazardous waste as defined in this division.

9th Annual California Unified Program Conference


Point of waste origination defined 22 ccr continued
Point of Waste Origination Defined 22 CCR (Continued)

  • [NOTE: In this case, this term is being used in a manner similar to the use of the term "point of generation" in air standards established for waste management operations under authority of the Clean Air Act in 40 CFR parts 60 , 61 and 63.]

9th Annual California Unified Program Conference


Point of waste generation defined per 40 cfr part 61
Point of Waste Generation Defined per 40 CFR part 61

  • Point of waste generation means the location where the waste stream exits the process unit component or storage tank prior to handling or treatment in an operation that is not an integral part of the production process, or in the case of waste management units that generate new wastes after treatment, the location where the waste stream exits the waste management unit component. (40 CFR Part 61)

9th Annual California Unified Program Conference


Points of generation
Points of Generation

  • Waste exits a non-waste unit or piece of equipment (e.g. radiator, parts washer).

  • Waste exits a manufacturing process unit.

  • Material is spent and a decision to discard or recycle is made.

  • Decision is made to discard a P or U listed chemical.

  • Treatment residue exits a treatment unit.

  • Residue exits a recycling unit.

9th Annual California Unified Program Conference


8 2 what is the point of generation
8.2 What Is the Point of Generation?

  • According to RCRA and Sate law, when a waste is generated, you must identify whether the waste is hazardous…

  • …hazardous waste identification must be made at the point where the waste is first generated. The point of generation is usually defined as the point at which a generator first determines that a material is no longer useful (or the point at which the generator decides to discard the material).

  • www.epa.gov/OSWRCRA/hazwaste/ ldr/ldr-sum.pdf

9th Annual California Unified Program Conference


8 2 what is the point of generation1
8.2 What Is the Point of Generation?

  • However, under 40 CFR 261.4(c), hazardous waste is not generated from product or raw material tanks…and pipelines, manufacturing process units, or associated non-waste-treatment-manufacturing units until it exits the unit; or the HW remains in unit > 90 days after the unit ceases to be operated for manufacturing, or for storage or transportation of product or raw materials.

  • www.epa.gov/OSWRCRA/hazwaste/ ldr/ldr-sum.pdf

9th Annual California Unified Program Conference


Points of generation pog tanks a b c
Points of Generation(POG) Tanks A, B & C

The Points Of Generation are

Process

A

Process

B

Process

C

Waste A

A + B

A+B+C=D

Tanks A, B & C contain material used in different processes; the piping is used exclusively to transfer the liquid when it is no longer useful.

Where is(are) the point(s) of generation?

D

9th Annual California Unified Program Conference


Commingling tanks a b c
ComminglingTanks A, B & C

The Points of Generation are also the

Sampling

points

Process

A

Process

B

Process

C

Waste A

A + B

A+B+C=D

Tanks A, B & C contain material.

The waste is commingled in the piping.

What and where do you sample

for a waste determination?

D

9th Annual California Unified Program Conference


Point of generation pog tanks a b c
Point of Generation (POG)Tanks A + B = C

Non-hazardous

Waste C

Is discharged to POTW

Acidic

Material

A

D002

Waste

Basic

Material

B

Waste A

A + B

A+B = C

C

Tanks A & B contain material; the piping is used to mix & transfer the liquid when it is no longer useful.

Where is (are) the point(s) of generation?

9th Annual California Unified Program Conference


Osw answer faxback 13395
OSW Answer (faxback 13395)

  • Q. A D002 acidic waste and a D002 basic waste from two different manufacturing process are individually piped to a collecting pipe. The two wastes neutralize each other in the collecting pipe and the result is a non-hazardous waste. Is there a point of generation?

  • A. Each of the corrosive wastes has a point of generation upstream of the collecting pipe.

9th Annual California Unified Program Conference


Faxback

FAXBACK?

What’s a FAXBACK?

It used to be an automated document fax system, hence the name.

9th Annual California Unified Program Conference


Rcra online
RCRA Online

  • Now it’s RCRA online.

  • http://www.epa.gov/rcraonline/

  • Select Advanced Search

  • http://yosemite.epa.gov/osw/rcra.nsf/advanced+search?OpenForm

  • Type the “faxback” number in the RCRA online number field.

  • Click on the Document name to view the entire document.

  • Like this….

9th Annual California Unified Program Conference



Type the “faxback”

Number in here.

9th Annual California Unified Program Conference





References
References

  • 22 CCR 6626x.xxx mirrors 40 CFR 26x.xxx

  • There are exceptions where is §66261.5?

    • 40 CFR 261.5 is CESQG, California does not use this concept (exceptions: LDRs, photochemical waste)

  • If the 22 CCR section reads exactly the same as the 40 CRF section the OSW guidance is probably good.

  • OSW, EPA, Faxbacks, Federal Registers All are good source document – even for California

9th Annual California Unified Program Conference


Http www dtsc ca gov
http://www.dtsc.ca.gov/

  • Check DTSC’s web page first, http://www.dtsc.ca.gov/

  • Publications Index

    • http://www.dtsc.ca.gov/database/Publications/pub_index.cfm

  • Forms Index

    • http://www.dtsc.ca.gov/database/Publications/forms_index.cfm

  • DTSC’s Hazardous Waste and Recycling Letters

    • http://www.dtsc.ca.gov/PublicationsForms/CSERFS/index.html

    • Some are out of date, the laws change.

9th Annual California Unified Program Conference



http://www.dtsc.ca.gov/HazardousWaste/CSERFS/index.cfm

9th Annual California Unified Program Conference


9 Files found out

of 848 files searched

9th Annual California Unified Program Conference


Treatment tier determination

Treatment Tier Determination

Where do you make a waste determination prior to entering a tiered permitting flow chart?

At the Point of Generation

9th Annual California Unified Program Conference


A decision is made to discard the material in tanks a b c then consolidate the waste in tank d
A decision is made to discard the material in tanks A, B & C, then consolidate the waste in tank D.

Process B

Process A

Process C

Points of generation

Waste Accumulation Tank. Waste D

Process B waste is non-hazardous. Processes A & C wastes are hazardous. Is this hazardous waste treatment?

No, it is not treatment if the wastes are combined solely for the purpose of consolidated accumulation.

9th Annual California Unified Program Conference


H sc 25123 4 b 1 treatment does not include
H&SC §25123.4 C, then (b) (1) "Treatment" does not include:

  • (C) Combining two or more waste streams that are not incompatible into a single tank or container if both of the following conditions apply:

    • (i) The waste streams are being combined solely for the purpose of consolidated accumulation or storage or consolidated offsite shipment, and they are not being combined to meet a fuel specification or to otherwise be chemically or physically prepared to be treated, burned for energy value, or incinerated.

    • (ii) The combined waste stream is managed in compliance with the most stringent of the regulatory requirements applicable to each individual waste stream.

9th Annual California Unified Program Conference


A decision is made to discard the material in tanks a b c then treat it in tank d
A decision is made to discard the material in tanks A, B & C, then treat it in tank D.

Process A

Process B

Process C

Points of generation

Treatment tank. Waste D

Process B waste is non-hazardous. Processes A & C wastes are hazardous. Waste D is hazardous.

Which waste(s) are used to determine the treatment tier?

Wastes A, C & D. Treatment Tier is based

on the hazardous waste characteristics (A & C) and the volume of waste treated (D).

9th Annual California Unified Program Conference


Because ca
Because? (CA) C, then

  • 25200.3 (b) Any treatment performed pursuant to this section shall comply with all of the following, except as to generators, who are treating hazardous waste pursuant to paragraph (11) of subdivision (a), who shall also comply with any additional conditions of the specified certification if those conditions are different from those set forth in this subdivision:

    • (1) The total volume of hazardous waste treated in the unit in any calendar month

9th Annual California Unified Program Conference


Because ce
Because? (CE) C, then

  • §25201.5. Generators, hazardous waste facility permit exemptions

    • (a) Notwithstanding any other provision of law, a hazardous waste facilities permit is not required for a generator who treats hazardous waste of a total weight of not more than 500 pounds, or a total volume of not more than 55 gallons, in any calendar month, if both of the following conditions are met:

9th Annual California Unified Program Conference


Caution
Caution C, then

  • H&SC 25200.3“(d) Notwithstanding any other provision of law, the following activities are ineligible for conditional authorization: (2) Commingling of hazardous waste with any hazardous waste that exceeds the concentration limits or pH limits specified in subdivision (a), or diluting hazardous waste in order to meet the concentration limits or pH limits specified in subdivision (a).

9th Annual California Unified Program Conference


A decision is made to discard the material in tanks a b c then treat it in tank d1
A decision is made to discard the material in tanks A, B & C, then treat it in tank D.

Process A

Process B

Process C

Points of generation

Treatment tank. Waste D

Process B waste is non-hazardous. Processes A & C wastes are hazardous. Waste D is non-hazardous.

Is the addition of waste B permissible dilution?

No, if waste B is added to dilute hazardous characteristics.

Yes, if waste B is added for efficient treatment.

9th Annual California Unified Program Conference


No 66268 3 dilution prohibited as a substitute for treatment
NO: C, then §66268.3. Dilution Prohibited As a Substitute for Treatment

  • (a) No generator, transporter, handler, or owner or operator of a treatment, storage, or disposal facility shall in any way dilute a restricted waste or the residual from treatment of a restricted waste as a substitute for adequate treatment to achieve compliance with article 4 or article 11 of this chapter, to circumvent the effective date of a prohibition in article 3 or article 10 of this chapter, to otherwise avoid a prohibition in article 3 or article 10 of this chapter, or to circumvent a land disposal prohibition imposed by RCRA section 3004 (42 U.S.C. § 6924).

9th Annual California Unified Program Conference


Yes dilution ref epa 530 r 01 007 revised august 2001
YES: Dilution C, then Ref: EPA 530-R-01-007 (revised August 2001)

  • Wastes that are aggregated or mixed as a part of a legitimate treatment process, and are subsequently diluted as a result, are not considered to be impermissibly diluted under LDR.

9th Annual California Unified Program Conference


A decision is made to discard the material in tanks a b c then treat it in tank d2
A decision is made to discard the material in tanks A, B & C, then treat it in tank D.

Process C

Process B

Process A

Points of generation

Waste Accumulation Tank. Waste D

Process B waste is non-hazardous. Processes A & C wastes are hazardous. Waste D isn’t hazardous, the addition of B reduced the hazardous constituents below the hazardous waste threshold. Is a treatment authorization required?

Yes, authorization is required. Waste A & C are hazardous waste. Dilution is treatment. Additional treatment might be required to meet LDR standards.


Treatment is
Treatment is C, then

  • 25123.5(a) “Treatment" means any method, technique, or process which is not otherwise excluded from the definition of treatment by this chapter and which is designed to change the physical, chemical, or biological character or composition of any hazardous waste or any material contained therein, or which removes or reduces its harmful properties or characteristics for any purpose.

9th Annual California Unified Program Conference


Land disposal restrictions ldrs
Land Disposal Restrictions C, then (LDRs)

  • LDRs were established to keep landfills from becoming superfund sites.

  • The dilution prohibition is in chapter 18 (LDRs).

  • But deactivation (DEACT) is a form of treatment permitted under LDRs that can be achieved by dilution.

  • The dilution reduce the toxics concentration below hazardous thresholds, then water could evaporate in non-hazardous waste surface impoundments and the resultant sludge could be hazardous and leach, so stringent treatment standards were mandated by the courts.

9th Annual California Unified Program Conference


LDR Treatment Standards Example: C, then D006 Sludge w/Cadmium

  • HAZARDOUS WASTE THRESHOLD

  • D006: Cadmium concentration  1.0 mg/l TCLP or STLC

  • Ni concentration  20 mg/l STLC

  • LDR TREATMENT STANDARDS

  • D006 waste water treatment standard 0.69 mg/l TCLP, notification on-file is the only requirement if discharged to POTW

  • D006 non-waste water treatment standard 0.11 mg/l (§§66268.40 & 66268.48)

  • Ni waste water treatment standard 3.98 mg/l (§66268.48)

  • Ni non-waste water treatment standard 0.11 mg/l TCLP (§66268.48)

9th Annual California Unified Program Conference


Treatment tier determination treatment units in series
Treatment Tier Determination C, then Treatment Units in Series

Process

Tank

Process Tank outflow (Waste A) Non-hazardous

Settling

Tank

Settling Tank sludge outflow

(Waste B), hazardous waste.

Sludge. Hazardous Waste

Waste B. Must have hazardous waste to have hazardous waste treatment.

Heated Drying Tank

Q: Which waste is used to

determine treatment tier,

A or B?

Non-hazardous waste water to sewer

9th Annual California Unified Program Conference


Treatment trick question
Treatment C, then Trick Question

NO. Fluoride salts are a Non-RCRA hazardous Waste.

HF

NaOH

D002

Waste

waste HF

HF+NaOH

H2O+NaF

The D002 waste from tanks A & B are neutralized in the collection piping. Is it OK to discharge the new waste (water & sodium fluoride) to sewer?

9th Annual California Unified Program Conference


Is the sodium fluoride subject to ldrs
Is the Sodium Fluoride subject to LDRs? C, then

No. The non-RCRA Wastes that are subject to Land Disposal Restrictions are listed in §§66268.29. Fluoride salts are not listed.

But, if the fluorine was from a P056 listed waste LDRs would apply!

9th Annual California Unified Program Conference


Treatment standard determination waste mixture
Treatment Standard Determination C, then -Waste Mixture-

Non-Haz

WasteA

Non-Haz

Waste B

Hazardous

Waste C

Treatment tank

Hazardous

Waste D

Wastes A & B are non-hazardous. Wastes C & D are hazardous. Waste D is dried and disposed of in a class I landfill. Which waste(s) do you evaluate to meet LDRs?

Waste C and D. The treatment standard is based on the waste at point of generation.


Treatment standard determination characteristic waste
Treatment Standard Determination C, then -Characteristic Waste-

Process

Tank

Process Tank outflow (waste A). Non-RCRA, Ni > 20 mg/l STLC

Settling

Tank

Settling tank sludge outflow

(waste B), RCRA, D006 (Cd) and Non-RCRA Ni.

Sludge, Hazardous Waste

Heated Drying Tank

Which wastes are subject to LDR standards?

All. The process waste (A) which goes out as wastewater (C) requires a notification to file. The outflow (B) which goes out as sludge is subject to RCRA & Calif. LDRs.

Pre-treated

Waste water

(Waste C) to POTW.

9th Annual California Unified Program Conference


Sludge
Sludge C, then

  • D006: Cadmium concentration  1.0 mg/l TCLP

  • Ni concentration  20 mg/l STLC, 2000 mg/kg TTLC

  • TREATMENT STANDARDS

  • D006 waste water treatment standard 0.69 mg/l TCLP, but one notification on-file only requirement if discharged to CWA facility (§§66268.40 & 66268.48)

  • D006 non-waste water treatment standard 0.11 mg/l (§§66268.40 & 66268.48)

  • Ni waste water treatment standard 20 mg/l WET (§66268.107)

9th Annual California Unified Program Conference


Waste water no land disposal no ldr
Waste water C, then No Land Disposal, No LDR

  • 22 CCR §66268.7 requires that the facility must place a one time notification in its files indicating that it is exempt from LDRs per §66261.4(a)(1), and (3) identifying the disposition of the waste.

  • Note: The underlying hazardous constituents do not have to be identified or treated in characteristic waste when these waste are de-characterized and managed in wastewater treatment systems regulated under the CWA.

9th Annual California Unified Program Conference


Treatment standard determination listed waste
Treatment Standard Determination C, then -Listed Waste-

Process

Tank

Process Tank outflow (waste A). RCRA F006

Settling

Tank

Settling tank sludge outflow

(waste B), RCRA F006

Sludge. Hazardous waste

Heated Drying Tank

Which wastes are subject to LDRs?

Process outfall (A) & sludge (B) require LDRs. Wastewater to POTW requires notice to file.

Pre-treated

Waste water

to POTW

9th Annual California Unified Program Conference


F006 sludge
F006 Sludge C, then

ConstituentWaste WaterNon-waste Water

  • Cadmium 0.69 mg/l 0.11 mg/l TCLP

  • Chromium 2.77 0.60 mg/l TCLP (total)

  • Cyanides 1.2 590.0 (total)

  • Cyanides 0.86 30 (amenable)

  • Lead 0.69 0.75 mg/l TCLP

  • Nickel 3.98 11.0 mg/l TCLP

  • Silver NA 0.14 mg/l TCLP

9th Annual California Unified Program Conference


Commingling diluting hazardous waste
Commingling (diluting) Hazardous Waste C, then

The waste from tank A is hazardous.

The wastes from tanks B & C are not

Hazardous

Haz

A

Not

B

Not

C

Hazardous

?

Is this dilution permitted?

Is this treatment?

Non-hazardous

D

Do LDRs apply?

9th Annual California Unified Program Conference


Commingling ref epa 530 r 01 007 revised august 2001
Commingling C, then Ref:EPA 530-R-01-007 (revised August 2001)

  • Where a waste stream will eventually be commingled with other waste streams, the Agency generally requires waste identification and LDR determination to be made at the point the waste is generated, prior to the commingling, even if the commingling occurs within a pipe (except in a totally enclosed treatment system). One exception to this rule is that the point of generation for tank cleanouts occurs at the end of the rinseouts in the receiving rinsate tank, even though the first rinse is likely to be of higher concentration than the other rinses.

9th Annual California Unified Program Conference


Is this dilution permitted
Is this Dilution Permitted? C, then

  • “Aggregation for Centralized Treatment” is generally acceptable dilution provided that the type of treatment will remove or destroy the contaminants.

  • You can’t aggregate to dilute, but you can aggregate for efficient treatment.

  • Wastes that are aggregated or mixed as a part of a legitimate treatment process, and are subsequently diluted as a result, are not considered to be impermissibly diluted under LDR.

9th Annual California Unified Program Conference


Is it treatment
Is it Treatment? C, then

H&SC §25123.4 (b) (1)Treatment does not include:

  • (C) Combining two or more waste streams that are not incompatible into a single tank or container if both of the following conditions apply:

    • (i) The waste streams are being combined solely for the purpose of consolidated accumulation or storage or consolidated offsite shipment, and they are not being combined to meet a fuel specification or to otherwise be chemically or physically prepared to be treated, burned for energy value, or incinerated.

    • (ii) The combined waste stream is managed in compliance with the most stringent of the regulatory requirements applicable to each individual waste stream.

9th Annual California Unified Program Conference


Do ldrs apply
Do LDRs Apply? C, then

  • These wastes are subject to land disposal restrictions. Removing the characteristic of corrosivity by combining these wastes can satisfy the treatment requirement of deactivation set out in 40 CFR 268.42, (now 268.40) Table 2. Dilution may not be appropriate if there are other requirements for the waste matrices. (FAXBACK 13395)

  • Combining waste acid & a waste caustic to remove the characteristic of corrosivity is regulated treatment in California.

9th Annual California Unified Program Conference


Recycling ldrs
Recycling & LDRs C, then

  • A generator that recycles onsite is still subject to LDRs.(FAXBACK 13280)

9th Annual California Unified Program Conference


Short break
Short Break C, then

  • Take 5

  • John Misleh, next speaker.

9th Annual California Unified Program Conference


Point of generation1

Point of Generation C, then

Tanks

&

Containers

9th Annual California Unified Program Conference


Hazardous waste determination point of generation pog
Hazardous Waste Determination C, then & Point of Generation (POG)

Process

Tank 1

Process Tank outflow (waste A). Non-hazardous

Process

Tank 2

Settling tank sludge outflow

(waste C) hazardous waste.

B

Sludge (waste B) hazardous waste.

A: The outflow from the Process Tank - Waste C – is hazardous and is the POG.

Heated Drying Tank

Q: Where is the point of generation? A or B or C?

Non-hazardous waste water to sewer.


Hazardous waste determination point of generation pog1
Hazardous Waste Determination C, then & Point of Generation (POG)

Process

Tank

Process Tank outflow (waste A). Non-hazardous

Settling

Tank

Settling tank sludge outflow

(waste C), hazardous waste.

B

Sludge (waste B) hazardous waste.

A: The settling tank - Waste B – is hazardous and is the POG.

Heated Drying Tank

Q: Where is the point of generation? B or C?

Non-hazardous waste water to sewer.


Hazardous waste determination point of generation pog2
Hazardous Waste Determination C, then & Point of Generation (POG)

Waste Tank input Non-hazardous waste.

A: The settling tank sludge is hazardous, the POG is in the tank.

Settling

Tank

A

Sludge

is Hazardous

Q: Where is the point of generation?

9th Annual California Unified Program Conference


Pog in a tank 66261 4 c exclusion
POG in a Tank C, then §66261.4(c) Exclusion

  • Ahazardous waste which is generated in a product or raw material storage tank is not subject to regulation under this divisionuntil it exits the unit in which it was generated unless the hazardous waste remains in the unit more than 90 days after the unit ceases to be operated.

  • The exemption in this subsection applies only to the hazardous waste generated in the above-named tanks, not to the tanks themselves. The tanks remain subject to the requirements of chapter 32 if the tank is a hazardous waste pursuant to article 3 of chapter 11 ofthis division.

9th Annual California Unified Program Conference


Pog in a tank
POG in a Tank C, then

  • Hazardous Waste is exempt if generated in:

    • A product or raw materials storage tank

    • A product or raw material transport vehicle or vessel

    • In a product or raw material pipeline

    • In a manufacturing process unit or an associated

    • Non-waste treatment-manufacturing unit

  • Until it exits the unit

  • Or remains in non operational unit for more than 90 days

  • Or unless the unit is a surface impoundment

9th Annual California Unified Program Conference


Pog in a tank1
POG in a Tank C, then

  • FAXBACKs

  • 11420

  • 12865

  • 11102

  • 11588

  • 14152

9th Annual California Unified Program Conference


Management of Tanks C, then

§67383.1. Applicability

Does you use this closure process?

When?


Chapter 32. Management of Tanks C, then

  • Use the Closure Process if :

    • The Tank System is identified as Hazardous Waste

  • And the Tank System is not:

    • “Scrap Metal”

9th Annual California Unified Program Conference


Hazardous waste
Hazardous Waste C, then

Photo BankPoints of Generation for Hazardous Waste

9th Annual California Unified Program Conference


Point of generation2
Point of Generation C, then

The following slides depict points of

generation where hazardous waste is being produced.

Do you agree?

9th Annual California Unified Program Conference


Drum Washing C, then

Point of Generation?

9th Annual California Unified Program Conference


Drum Washing C, then

Point of Generation?

When rinsate exits

the process unit

A

When rinsate exits

the drum

B

The empty drum

is the POG

C

The drum is not California empty

9th Annual California Unified Program Conference


Drum Washing C, then

Point of Generation?

When rinsate exits

the process unit

A

B

When rinsate exits

the drum

The empty drum

is the POG

C

What if the drum is California empty?

9th Annual California Unified Program Conference


Drum Washing C, then

Point of Generation?

Is the Drum Washing still Tiered Permitting?

How about rinsing 5 gallon pails?

What if the drum is California empty?

9th Annual California Unified Program Conference


Process Tanks C, then

Point of Generation?

9th Annual California Unified Program Conference


Process Tanks C, then

Point of Generation?

A

When solution is removed as a waste

Is a product not a waste?

When solution remains in non-operational equipment for >90 days

When solution remains in non-operational equipment for > 1 year

B

C

9th Annual California Unified Program Conference


HCl Bottling Area C, then Poly Tank

Point of Generation?

9th Annual California Unified Program Conference


HCl Bottling Area C, then Poly Tank

Point of Generation?

A

Exit point from tank

B

The sump

When removed from the sump

C

9th Annual California Unified Program Conference


Floor of Plating Shop C, then

Point of Generation?

9th Annual California Unified Program Conference


Floor of Plating Shop C, then

Point of Generation?

X

Floor is part of process, not a waste

9th Annual California Unified Program Conference


Floor of plating shop point of generation
Floor of Plating Shop C, then Point of Generation?

X

Floor is part of process, not a waste

9th Annual California Unified Program Conference


Floor of plating shop point of generation1
Floor of Plating Shop C, then Point of Generation?

Haz. Material/Waste Dropped on the Floor

9th Annual California Unified Program Conference


Floor of Plating Shop C, then Point of Generation?

Leaking Nickel Tank

9th Annual California Unified Program Conference


The waste determination treatment tier land disposal restrictions are all based on

The Waste Determination C, then Treatment Tier Land Disposal Restrictions are all based on

The Point of Generation

9th Annual California Unified Program Conference


Ten minute break
Ten minute Break C, then

Take a Break?

Please be back by

9th Annual California Unified Program Conference


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