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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

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cfr 40
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
Training Objectives
  • Understand types of waste generators
  • Define hazardous wastes
  • Describe proper handling and storage of 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
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
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
What is a hazardous waste?
  • A solid waste, or combination of solid wastes, 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
What is a hazardous waste? Contd
  • Listed Wastes – automatically hazardous if it is 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 contd1
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 waste
  • RBP is a small quantity generator
  • Primary hazardous waste is solvent from tank 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
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
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 waste1
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
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
Reactive Waste If
  • ( Code D003 )
  • 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
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
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
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
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.
hazardous waste identification1
Hazardous Waste Identification
  • Once container is full, the date is entered on the 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
Waste Transport
  • Transport only by licensed Hazardous Waste Hauler
  • Shipment not accepted without a manifest signed by the 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
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
Manifest info continued
  • US DOT description of wastes including 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
EPA Hazardous Waste ID Numbers
  • 40CFR261 Identification and listing of hazardous waste
  • D001 is code for our ignitable solvent waste
universal 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
Universal Wastes
  • Label as Universal Waste –Lamp(s)
  • Universal Waste – Pesticide(s)
  • Etc.
waste minimization
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 off-spec/obsolete product or raw materials
alternate users must
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
Emergency response to a spill
  • 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
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.