Introduction to Managing Hazardous Waste Presented by: Steven Shaffer, CHMM Industrial Hygienist 1

Objectives Describe the major components of the Resource Conservation and Recovery Act (RCRA) Explain how to identify, and accumulate, hazardous waste in accordance with RCRA Describe how to properly label and prepare hazardous waste for disposal Introduce generator status requirements 3

I. What is the Resource Conservation & Recovery Act (RCRA)?

The U.S. Environmental Protection Agency The mission of the U.S.E.P.A. is to protect human health and to safeguard the natural environment -- air, water, land, upon which life depends. - 1999 EPA strategic plan -

Resource Conservation & Recovery Act (RCRA) Enacted in 1976 by EPA as an amendment to the Solid Waste Disposal Act (SWDA) Main objectives: Protect human health & the environment conserve valuable material & energy resources Established "Cradle-to-grave" management and tracking of hazardous waste EPA inspectors have same authority as FBI/ATF 5

RCRA Administration EPA administers RCRA States may be authorized by the EPA Iowa does not administer state program RCRA program in Iowa is administered directly by the EPA Region VII, in Kansas City, Kansas

USEPA Regions

II. Identification of Chemical Hazardous Waste

Two Steps of Hazardous Waste Management 1. What is hazardous waste? 2. How do I collect my hazardous waste? 11

What is Hazardous Waste? Used Chemicals Expired chemicals Old chemicals without expiration dates Waste “test” What is this chemical? How do I use it? How often is it used? Is the material still suitable for its intended use?

Criteria for Determining Hazardous Waste Listed (EPA activity) Characteristics (generator activity) Ignitable Toxic Corrosive Reactive 6

Listed Waste Unused or off-specification materials U-List, Toxic and other P-List, Acutely toxic materials Used material or mixture of solvents F-list, Hazardous waste from nonspecific sources, spent solvents D-list, toxic materials

Characteristic Waste Ignitable Corrosive Flammable liquids, flashpoint < 60 C (140 F) Oxidizers, Organic Peroxides, Flammable compressed gasses Any material, other than a liquid, that is capable of spontaneous and sustained combustion under standard temperature and pressure. Corrosive Aqueous liquids with a pH < 2 or pH > 12 Inorganic acids, Organic acids, Bases

Characteristic Waste Cont. Reactive Materials which can react violently or create toxic fumes. Sulfides,Cyanides, Peroxide formers, Alkali metals, Dinitro, Trinitro compounds, Carbonyl compounds, isocyanates, and perchlorate crystal formers Toxic This includes 8 heavy metals, 10 pesticides, and 21 organic compounds. D-list

III. Packaging Hazardous Waste

Packaging Your Waste for Disposal Compatible containers Lids Screw-cap containers are best Labeled 11

Labeling Label all chemical waste containers with the word “Hazardous Waste", e.g., “Hazardous Waste, Acetone" Permanent labels Utilize proper chemical name or common names Do not use formulas, symbols or structural configurations State active ingredients when using trade names 18

Waste Segregation Compatible Inorganic vs. organic Halogenated vs. non-halogenated Pump oil Compressed gas cylinders Sharps in puncture-proof containers (needles, syringes, razor blades) 12

Unknown Chemicals Unknowns are serious EPA violations Prevention of Unknowns Maintain legible labels Review and rotate chemical stock Keep proper inventory records 29

Empty Containers A container is empty if all wastes have been removed using common practices for the type of container. Triple rinse P-listed waste containers and handle rensate as hazardous waste. Remove label. Dispose of empty containers in the normal refuse. 14

IV. Generator Status

Generator Status Conditionally Exempt Small Quantity Generator Large Quantity Generator

Generator Requirements Cont. Conditionally Exempt Small Quantity Generator (CESQG) Identify all Hazardous Waste generated Send all hazardous waste to a permitted hazardous waste management facility.

Generator Status Cont. Conditionally Exempt Small Quantity Generator (CESQG) Generate < 100 Kg Hazardous Waste and < 1 Kg P - list in a calendar month Accumulate no more than 1,000 Kg of Hazardous Waste at any time

Generator Requirements Cont. Small Quantity Generator (SQG) Register, obtain EPA ID number Comply with Hazardous Waste container requirements in 40 CFR 265. Meet requirements of Satellite Accumulation Areas, (SAA) Provide an Emergency Response Coordinator Post the name and phone number of emergency response coordinator, location of spill kit, fire alarm, fire extinguisher, and fire department number near phone

SQG Requirements Cont. Ensure employees know how to respond to emergencies and how to handle hazardous waste Establish record keeping on: Procedures for waste characterization Documentation on generator status Registration Manifests Container inspection Land Disposal Restrictions (LDR) Correspondence with local emergency responders

Generator Requirements Large Quantity Generator (LQG) Register, obtain EPA ID number Comply with Hazardous Waste container requirements in 40 CFR 265. Meet requirements of Satellite Accumulation Areas, (SAA) and accumulation areas Prepare a Contingency Plan Develop and implement a formal training program Maintain record keeping as a SQG and include training records, contingency planning, and biannual reporting.

Summary of Generator Status Requirement (40 CFR) CESQG SQG LQG Waste determination yes Generation Rate limits < 100 Kg/month 100-1000 Kg/month >1000 KG/ month Accumulation limit w/o Permit < 1000 Kg at any time < 6000 Kg No limit < 1 Kg P-list Accumulation time N/A 180 days 90 days EPA ID number Start date "Hazardous Waste" Air emission standard Satellite Accumulation Use Manifests Exception Reporting Required after 35 days Required after 45 days Biennial Report Contingency Plan Basic Planning Full written plan RCRA Training Basic training Full Compliance Storage Requirements Yes Record Keeping Waste Determination Generation log

How do I dispose of my waste? If you are LQG or SQG you must use an Environmental Services company. If you are CESQG you can use the Household Hazardous Materials Regional Collection Centers Iowa waste exchange program

HHM Regional Collection Centers

Resources Iowa Waste Reduction Center Iowa Waste Exchange Iowa DNR www.iwrc.org/index.htm Iowa Waste Exchange www.iowadnr.com/waste/iwe/index.html Iowa DNR www.iowadnr.com Regional Collection Centers www.iowadnr.com/waste/hhm/index.html EPA Region 7 www.era.gov/Region7

Questions???