WELCOME

1. HAZARDOUS WASTE MANAGEMENT CUSTOMIZED ENVIRONMENTAL TRAINING WELCOME

2. INSTRUCTOR Insert Instructor Name Here

3. OBJECTIVES • Define Hazardous Waste. • Discuss the Different Types of Generators. • Discuss the EPA Identification Number. • Discuss Container Management. • Discuss Hazardous Waste Accumulation Area Requirements. • Discuss Transportation Requirements. • Examine the Contents of a Contingency Plan. • Discuss the role of the Emergency Coordinator. • Discuss Training Requirements. • Discuss Inspection Procedures. • Discuss Use of Contractors.

4. GOALS • Understand the Definition of a Hazardous Waste. • Understand the Different Types of Hazardous Waste Generators. • Understand How to Manage a Hazardous Waste Container. • Be Familiar With the Requirements of a Hazardous Waste Accumulation Area. • Understand the Transportation Requirements and Reports. • Understand the Contents of a Contingency Plan. • Understand the Role of a Emergency Coordinator. • Understand the Inspection Criteria of a Hazardous Waste Accumulation Area.

5. BACKGROUND • More than 250 million tons of hazardous waste is generated in the United States annually. That is roughly the equivalent of 1 ton per person. • More than 70,000 types of chemicals are used regularly throughout the world. • There are more than 37,000 illegal hazardous waste dumps in the United States that threaten groundwater and citizen’s health. • This training helps improve environmental compliance with the Resource Conservation Recovery Act (RCRA).

6. LEARNERS • Supervisors • Facility Engineers • Maintenance Personnel • Department Managers • Building Occupants • Process Specialists • Hazardous Waste Handlers • Environmental and Safety Committees

7. OVERVIEW The goal of this course is to provide supervisors with the tools needed to properly manage a hazardous waste program. It recommends practical, actions that can be carried out by facility management, maintenance personnel and building occupants. The course will help you to integrate good hazardous waste management practices into your existing organization and identify which of your staff have the necessary skills to carry out those activities.

8. WHAT THIS COURSE DOES NOT DO The course is not intended to provide 40 Hour, 24 Hour training or 8 Hour Refresher Training as directed by 29 CFR 1910.120. However, it can be used as part of the equivalent training as recommended in 29 CFR 1910.120. Both 40-Hour and 24-Hour Training and the 8-Hour Refresher Training require specialized training beyond the intended scope of this course. Where this expertise is needed, outside assistance should be solicited.

9. RCRA addresses both hazardous waste and solid waste. Subtitle C of RCRA, 42 U.S. Code (USC) sections 6921-6939b, establishes standards and procedures for the handling, storage, treatment, and disposal of hazardous waste. EPA regulations 40 CFR Parts 260-299 establish a “Cradle-to-Grave” system. RESOURCE CONSERVATION AND RECOVERY ACT (RCRA)

10. Pertinent Regulations: 40 CFR 261 – Identification and listing of hazardous wastes. 40 CFT 262 – Standards applicable to generators of hazardous waste 29 CFR 19010.120 – Hazardous waste operations and emergency response. FEDERAL REGULATIONS

11. EPA encourages states to develop their own regulatory Hazardous Waste (HW) programs. States’ regulatory programs must be at least as stringent as the federal EPA regulatory requirements. Not all states have developed a program. States’ programs may differ from EPA program. Facilities are required to comply with either the federal EPA requirements or the state’s requirements, whichever is the most stringent. This training course utilizes federal EPA regulations. STATE REGULATIONS

12. Proper identification of hazardous wastes is a complex task that is fundamental to determining which materials at a facility are subject to the Resource Conservation and Recovery Act (RCRA) requirements. Four Questions: Do the regulations consider the waste to be a solid waste? Is there an exclusion for the waste? Is the waste listed or have the characteristics of a hazardous waste? Has the waste been delisted? WHAT IS A HAZARDOUS WASTE?

13. RCRA defines a hazardous waste as one that “causes or significantly contributes to an increase in mortality or an increase in serious irreversible, or incapacitating reversible illness; or poses a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, disposed of, or otherwise managed.” A SIMPLIFIED DEFINITION

14. Any solid waste that exhibits one or more of these characteristics is classified as hazardous under RCRA: Ignitability Corrosivity Reactivity or Toxicity CHARACTERISTICS OF A HAZARDOUS WASTE

15. EPA has three categories of listed wastes: Nonspecific source wastes – Examples include: - Spent halogenated solvents used in degreasing. - Wastewater treatment sludge. Specific source wastes – Examples include: - Wood preserving residues. - Petroleum refining wastes. Commercial chemical products – Examples include: - Chloroform - Creosote LISTED HAZARDOUS WASTES

16. Acutely hazardous wastes are wastes that EPA has determined to be so dangerous that small amounts are regulated in a manner similar to larger amounts of hazardous wastes. Examples of acutely hazardous wastes include: Arsenic Oxide Benzene Carbon Disulfide Mercury Sulfuric Acid ACUTE HAZARDOUS WASTES

17. Conditionally Exempt Small Quantity Generator (CESQG) • CESQGs: • Generates no more than 100 kg (220.46 lb.) of hazardous waste or 1 kg (2.20 lb.) of acutely hazardous waste in a calendar month. • Accumulates no more than 1,000 kg (2,204.62 lb) of hazardous material at any one time.

18. SQGs: Generates between 100 kg (220.46 lb.) and 1,000 kg (2,204.62 lb) of hazardous waste in a calendar month. Can not accumulate more than 180 days on site unless waste is to be transported more than 200 miles, then it can accumulate 270 days. Accumulates no more than 6,000 kg (13,227.73 lb) of hazardous material or 1 kg (2.20 lb) of acutely hazardous material at any one time. SMALL QUANTITY GENERATOR(SQG)

19. LQGs: Generates greater than 1000 kg (2204.62 lb.) of hazardous waste or 1 kg (2.20 lb.) of acutely hazardous waste in a calendar month. Accumulates no more than 90 days on site. LARGE QUANTITY GENERATORS(LQG)

20. TIME LIMITS FOR HW ACCUMUMULATION AND STORAGE Time Limit Definitions: Accumulation: the initial amount of hazardous waste that is collected before the storage time limit applies. Storage: the holding of containerized or isolated hazardous wastes either at the point of generation or at a specially designed storage area.

21. TIME LIMITS FOR HW ACCUMUMULATION AND STORAGE • LQGs: • 90 Day Rule for Accumulation • SQGs: • 180 Days • 270 Days if shipped >200 miles. • CESQGs: • None

22. A generator must not treat, store, dispose of, transport, or offer for transportation, hazardous waste without having received an EPA identification number. EPA and states use these 12-character numbers to monitor and track hazardous waste activities. Call the Regional EPA to obtain an EPA Identification Number. EPA ID NUMBER

23. Must minimize the possibility of fire. Assigned personnel shall be responsible. Storage areas shall be marked: “DANGER HAZARDOUS WASTE AREA – UNAUTHORIZED PERSONNEL KEEP OUT” SECURITY

24. A 24-hour surveillance system. OR An artificial or natural barrier which completely surrounds the active portion of the facility (e.g., fence). A sign reading: "Danger - Unauthorized Personnel Keep Out" SECURITY

25. INCOMPATIBLE WASTES Wastes are incompatible for: • May cause corrosion or decay of containment materials (e.g., container liners or tank walls) or • Commingling with another waste or material under uncontrolled conditions may cause a fire, explosion or another type of undesirable reaction.

26. IGNITABLE OR REACTIVE WASTES • Use safe management practices to handle incompatible wastes. • Separate incompatible wastes using a dike, wall, berm, or other device. • Keep ignitable or reactive wastes at least 50 feet from property line.

27. CONTAINER MANAGEMENT Empty Containers Previously Holding Hazardous Wastes Must: • Have no more than 1 inch of residue remaining. • For containers over 110 gallons have no more than .3% of the total container weight remaining. • For compressed gasses, container’s pressure should approach atmospheric pressure. • For containers holding acute hazardous wastes, triple rinsed or equivalent cleaning.

28. CONTAINER MANAGEMENT • Keep containers closed. • Containers should be in good condition. • Containers and waste should be compatible. • Verify that handling and storage practices do not damage containers.

29. No more than 55 gal. Under the direct control of a single operator Waste is transferred to a storage area within three days. Only for SQG and LQG. SATELLITE ACCUMULATION POINTS

30. Containers must be in good condition. Containers must not be compatible with wastes. Containers are to be kept closed. The containers are marked HAZARDOUS WASTE. The containers are marked with the date accumulation began. SATELLITE ACCUMULATION AREAS

31. The least handling is the best handling. Standardize handling procedures. Plan ahead. Never exceed safety capacities. Learn the proper use of Material Handling Equipment. PRINCIPLES OF MATERIALS HANDLING

32. Labeling Requirements: The accumulation start date and/or the date the 90-day storage period began; The words “Hazardous Waste”; The composition and physical state of the wastes; Warning words indicating the particular hazards of the waste The name and address of the facility Before transportation off-site, a generator must label each package in accordance with Department of Transportation regulations. CONTAINER LABELING

33. Containers are not stored more than 2 high and have pallets between them Containers of highly flammable wastes are electrically grounded At least 3 ft. of aisle space is provided between rows of containers. AISLE SPACE

34. Each area must have both: Internal – Voice or alarms to warn facility personnel. External –Telephone, hand-held two way radio capable of contacting emergency responders. COMMUNICATIONS

35. Portable fire extinguishers and fire control equipment. Spill control equipment Decontamination equipment Fire hydrants or other source of water Showers or eyewash facilities. Emergency equipment should be checked periodically to insure they are working properly. EMERGENCY EQUIPMENT Other Emergency Equipment in Storage Areas:

36. Responsibility of wastes is “cradle-to-grave.” Facility could still be liable for the hazardous waste after it leaves your facility. Ensure transporters and TSDFs have an EPA Identification number and the required permits. Transporters and TSDFs should have a good regulatory record. TRANSPORTERS AND FACILITIES RECEIVING WASTES

37. Generators of Hazardous Waste are Required to use Manifests. Signed Copies of Returned Manifests Must be Kept for Three Years. Manifests Not Required for Recycling of Hazardous Wastes. Retention of Records is Extended Automatically During Unresolved Enforcement Actions. MANIFESTS

38. Exception reports must be submitted to the regulatory agency when a signed manifest copy was not received within 60 days of the waste being accepted by the initial transporter. Exception reports must be filed when certain delays or difficulties occur when exporting hazardous waste out of the United States. Exception reports must be kept for at least three years. EXCEPTION REPORT

39. Generators who shipped hazardous waste off-site must submit a biennial report by 1 March of even numbered years. The Biennial Report Form (EPA Form 8700-13A) is to be submitted in at timely manner. Copies of Biennial Report are to be kept for at least three years. BIENNIAL REPORT

40. Generators must have a contingency plan. The contingency plan should be designed to minimize hazards to human health or the environment The plan needs to include the following: - A description of actions to be taken during an emergency - A description of arrangements. - Names, addresses, and phone numbers of emergency coordinators - A list of all emergency equipment - An evacuation plan CONTINENCY PLAN

41. Copies of the contingency plan and all revisions are maintained at the facility and organizations which may be called upon to provide emergency services. The contingency plan needs to be routinely reviewed and updated, especially when: - The applicable regulations are revised - The plan fails in an emergency - The facility changes - The list of emergency coordinators changes - The list of emergency equipment changes. CONTINENCY PLAN

42. Generator operators must record the time, date, and details of any incident that requires implementing the contingency plan. A written report has to be submitted to the governing regulatory agency within 15 days after the incident. AFTER AN INCIDENT

43. Each generator must have an emergency coordinator on the facility premises or on call at all times. The emergency coordinator is to be thoroughly familiar with the facility operations and the contingency plan. The following information needs to be posted next to telephones and at the hazardous waste accumulation site: - Name and telephone number of emergency coordinator - Location of fire extinguishers and spill control materials - Location of fire alarms (if present) - Telephone number of fire department. EMERGENCY COORDINATOR

44. Emergency Coordinators During an Emergency Must: Immediately activate facility alarms or communication systems Identify the character, exact source, amount, and a real extent of any released materials Assess possible hazards to human health or the environment Take all reasonable measures necessary to ensure that fires, explosions and releases do not occur, recur, or spread to other hazardous waste at the facility. EMERGENCY COORDINATOR

45. These measures must include where applicable: Stop processes and operations at the facility Monitor for leaks, pressure buildup, gas generation Provide for treatment, storage, or disposal of recovered waste, contaminated soil, or surface water, or other material immediately after emergency Ensure that no waste that may be incompatible with the released material is treated, stored, or disposed of until cleanup is completed Ensure that all emergency equipment is cleaned Notify regulators EMERGENCY COORDINATOR

46. All personnel who handle hazardous waste must meet certain training requirements. The training program should be directed by a person trained in hazardous waste management procedures. Potential topics include: - Waste turn in procedures - Identification of hazardous wastes - Container use, marking, labeling and on-site transportation - Manifesting and off-site transportation - 90 day storage area management - Personal health and safety and fire safety TRAINING

47. Training program needs to include contingency plan implementation. This should include where applicable: - Automatic waste feed cut-off systems - Emergency and monitoring equipment - Operation of communications and alarm systems - Response to fire or explosion - Response to groundwater contamination incidents - Response to leaks or spills - Shutdown of operations. TRAINING

48. The new employee training must be completed within six months. Need an annual review of initial training. No unsupervised employees until training is complete. Waste storage area managers and hazardous waste handlers have to have required training. TRAINING

49. Must maintain training records all facility staff who manage hazardous waste. The training records shall include: - Job title and description - Written description of how much training each position will obtain - Documentation of training received by name. Training records are to be retained for three years after an employee leaves the facility. TRAINING RECORDS

50. Facilities are required to have a written plan and schedule for inspection and monitoring requirements for containers and meet specific inspection requirements. Logs and checklists should be specific to facility being inspected. GENERAL INSPECTION REQUIREMENTS