Smithfield 2012 Environmental Conference Hazardous Waste By Susan Murphy, FFI

Hazardous Waste Most facilities are SQG or CESQG CESQG means less than 220 lbs hazardous waste generated in ANY calendar month Hazardous wastes are either Listed (P- U- D-toxic lists ), listed process (F-list for nonspecific sources), or characteristic (D001,Doo2,Doo3)

Hazardous Waste a word about inspections… Any unmarked container is a potential hazardous waste violation Why does the RCRA inspector look at our Universal Waste collection locations? It is OK to dump the expired cleaning chemical down the drain—OR IS IT?

Hazardous Waste Waste Determinations are key Every employee should feel confident that what they are doing is “legal” Wastes, at the point of generation, need to be characterized The facility needs a process to make hazardous waste determinations

Hazardous Waste ask the EC The lab botches a titration and the endpoint pH is 13. Can this go down the drain? Food safety calls and a damaged bag of sodium nitrite needs to be gotten rid of. What can they do with it? We have metal cans that held epoxy paint. Can these go in the trash dumpster? You find a broken fluorescent light bulb. What should you do with it? Safety Kleen picks up and recycles parts washer solvent. So this is not a hazardous waste, right?

DEFINITION OF A SOLID WASTE All materials FIGURE 1 DEFINITION OF A SOLID WASTE All materials Solid, liquid, semi-solid or contained gaseous material which is: Discarded Served its intended purpose A manufacturing byproduct OTHER GARBAGE, REFUSE OR SLUDGE Does 261.4(a) exclude your material from RCRA because it is one of the following:1.domestic sewage 2.CWA point source discharge 3. irrigation return flow 4. AEC source, special nuclear or byproduct material 5. in situ mining waste THE MATERIAL IS NOT A RCRA SOLID WASTE YES THE MATERIAL IS A RCRA SOLID WASTE IRRESPECTIVE OF WHETHER YOU DISCARD IT, USE IT, REUSE IT, RECYCLE IT RECLAIM IT, STORE IT, OR ACCUMULATE IT FOR PURPOSES OF 1.-5. ABOVE NO

DEFINITION OF A HAZARDOUS WASTE FIGURE 2 DEFINITION OF A HAZARDOUS WASTE Is the solid waste excluded from regulation under 261.4(b)? YES Is the solid waste listed in Part 261, Subpart D, or is it a mixture that contains a waste listed in Subpart D? NO Has the waste or mixture been excluded from the lists in Subpart D or 261.3 in accordance with 260.20 and 260.22? YES Does the waste exhibit any of the characteristics specified in Part 261, Subpart C? NO NO YES THE WASTE IS SUBJECT TO CONTRTOL UNDER SUBTITLE D (IF LAND DISPOSED) THE WASTE IS A HAZARDOUS WASTE. SEE FIGURE 3

SPECIAL PROVISIONS FOR CERTAIN HAZARDOUS WASTE FIGURE 3 SPECIAL PROVISIONS FOR CERTAIN HAZARDOUS WASTE THE WASTE IS A HAZARDOUS WASTE Is it generated by a small quantity generator as defined in 261.5? YES It is subject to the special requirements of 261.5 Therefore, it must be intended to be discarded. IT IS SUBJECT TO THE SUBTITLE C REGULATIONS IN FIGURE 4. Is it or is it intended to be legitimately and beneficially used, reused, recycled, or reclaimed? NO Is it a sludge or is it listed in Part 261 Subpart D or is it a mixture containing a waste listed in Part 261, Subpart D? NO IT IS NOT SUBJECT TO REGULATION UNDER SUBTITLE C. IT IS SUBJECT TO THE FOLLOWING WITH RESPECT TO ITS TRANSPORTATION OR STORAGE: Notification under Section 3010 Parts 262 and 263 Part 264, Subparts A through E Part 265, Subparts A through E, and G, H, I, J, and L Parts 270 and 124

REGULATIONS FOR HAZARDOUS WASTE NOT COVERED IN DIAGRAM 3 FIGURE 4 REGULATIONS FOR HAZARDOUS WASTE NOT COVERED IN DIAGRAM 3 All persons who handle hazardous waste subject to control under Subtitle C not covered in Figure 3 Notify EPA according to Section 3010 of RCRA and obtain EPA ID no. GENERATORS TRANSPORTERS OWNERS OR OPERATORS OF T/S/D FACILITIES On-site generators storing wastes for < 90 days for subsequent shipment off site All other Owners or Operators Part 262.34 Part 262 Part 262 Those qualifying for Interim Status Those who do not qualify http://www.epa.gov/waste/hazard/wastetypes/wasteid/char/hw-char.pdf Part 265

Hazardous Waste ?? Is it OK to save up my hazardous waste until the container is full to save money? ?? We are cleaning out an area and I found over 1,000 kg of wastes. Do I have to become a LQG? ?? The vendor preprints my manifests. They are responsible for the paperwork accuracy because I am paying them, right? A lab test uses a hazardous chemical in a large volume of sample. Can I decant the waste to reduce the volume before giving it to the vendor?

Polychlorinated Biphenyls (PCBs) 40 CFR Part 761 Transformers—Request the placement of a Non-PCB label even if it is owned by power company. Don’t forget to “look up” on power poles Do you have a SOP for plant maintenance and electricians? Where and how to store ballasts until the part number is verified as not containing PCBs Most landfills take PCB ballasts if they are not leaking.

Notification of Regulated Waste Activity EPA updated the Form and Instructions in 2011. This requirement is found in the notification requirements of RCRA Section 3010. http://www.epa.gov/osw/inforesources/data/form8700/8700-12.pdf All generators of hazardous waste are to submit a Notification of Regulated Waste Activity Form. IF YOU, AT ALL TIMES, FOLLOW ALL CESQG REQUIREMENTS OF 40 CFR 261.5, THEN YOU DO NOT HAVE TO FILE THIS FORM. If your status temporarily changes (i.e., from CESQG to SQG), file a form. Submit another one right away to change your status back! It is simple, easy, and F U N!!

Notification Form 8700-12 Section 3010 of Subtitle C of Resource Conservation and Recovery Act (RCRA) requires any person who generates, transports, or recycles regulated wastes or who owns or operates a facility for the treatment, storage, or disposal of regulated wastes to notify EPA of their activities, including the location and general description of the activities and the regulated wastes handled. Respondents must submit the information required in the Notification of Subtitle C Activity Instructions and Form booklet by completing the RCRA Subtitle C Site Identification Form [EPA Form 8700-12]. This is mandatory reporting by the respondents.

Hazardous Waste—Questions?