1. Hazardous Waste Management 1 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. WELCOME HAZARDOUS WASTE MANAGEMENT CUSTOMIZED ENVIRONMENTAL TRAINING

2. Hazardous Waste Management 2 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. INSTRUCTOR Insert Instructor Name Here

3. Hazardous Waste Management 3 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC.  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. OBJECTIVES

4. Hazardous Waste Management 4 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC.  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. GOALS

5. Hazardous Waste Management 5 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. 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. Hazardous Waste Management 6 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC.  Supervisors  Facility Engineers  Maintenance Personnel  Department Managers  Building Occupants  Process Specialists  Hazardous Waste Handlers  Environmental and Safety Committees LEARNERS

7. Hazardous Waste Management 7 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. 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. OVERVIEW

8. Hazardous Waste Management 8 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. 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. Hazardous Waste Management 9 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. RESOURCE CONSERVATION AND RECOVERY ACT (RCRA) 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.

10. Hazardous Waste Management 10 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. FEDERAL REGULATIONS 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.

11. Hazardous Waste Management 11 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. STATE REGULATIONS 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.

12. Hazardous Waste Management 12 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. WHAT IS A HAZARDOUS WASTE? 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: 1.Do the regulations consider the waste to be a solid waste? 2.Is there an exclusion for the waste? 3.Is the waste listed or have the characteristics of a hazardous waste? 4.Has the waste been delisted?

13. Hazardous Waste Management 13 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. A SIMPLIFIED DEFINITION 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.”

14. Hazardous Waste Management 14 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. CHARACTERISTICS OF A HAZARDOUS WASTE Any solid waste that exhibits one or more of these characteristics is classified as hazardous under RCRA: Ignitability Corrosivity Reactivity or Toxicity

15. Hazardous Waste Management 15 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. LISTED HAZARDOUS WASTES 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

16. Hazardous Waste Management 16 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. ACUTE HAZARDOUS WASTES 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

17. Hazardous Waste Management 17 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. 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. Hazardous Waste Management 18 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. SMALL QUANTITY GENERATOR (SQG) 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.

19. Hazardous Waste Management 19 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. LARGE QUANTITY GENERATORS (LQG) 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.

20. Hazardous Waste Management 20 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. TIME LIMITS FOR HW ACCUMUMULATION AND STORAGE 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. Time Limit Definitions:

21. Hazardous Waste Management 21 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. 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. Hazardous Waste Management 22 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. EPA ID NUMBER 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.

23. Hazardous Waste Management 23 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. SECURITY Must minimize the possibility of fire. Assigned personnel shall be responsible. Storage areas shall be marked: “DANGER HAZARDOUS WASTE AREA – UNAUTHORIZED PERSONNEL KEEP OUT”

24. Hazardous Waste Management 24 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. SECURITY 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"

25. Hazardous Waste Management 25 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. INCOMPATIBLE WASTES 1.May cause corrosion or decay of containment materials (e.g., container liners or tank walls) or 2.Commingling with another waste or material under uncontrolled conditions may cause a fire, explosion or another type of undesirable reaction. Wastes are incompatible for:

26. Hazardous Waste Management 26 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. 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. Hazardous Waste Management 27 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. CONTAINER MANAGEMENT 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. Empty Containers Previously Holding Hazardous Wastes Must:

28. Hazardous Waste Management 28 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. 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. Hazardous Waste Management 29 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. SATELLITE ACCUMULATION POINTS 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.

30. Hazardous Waste Management 30 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. SATELLITE ACCUMULATION AREAS 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.

31. Hazardous Waste Management 31 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. PRINCIPLES OF MATERIALS HANDLING The least handling is the best handling. Standardize handling procedures. Plan ahead. Never exceed safety capacities. Learn the proper use of Material Handling Equipment.

32. Hazardous Waste Management 32 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. CONTAINER LABELING 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.

33. Hazardous Waste Management 33 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. AISLE SPACE 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.

34. Hazardous Waste Management 34 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. COMMUNICATIONS 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.

35. Hazardous Waste Management 35 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. EMERGENCY EQUIPMENT 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. Other Emergency Equipment in Storage Areas:

36. Hazardous Waste Management 36 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. TRANSPORTERS AND FACILITIES RECEIVING WASTES 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.

37. Hazardous Waste Management 37 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. MANIFESTS 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.

38. Hazardous Waste Management 38 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. EXCEPTION REPORT 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.

39. Hazardous Waste Management 39 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. BIENNIAL REPORT 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.

40. Hazardous Waste Management 40 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. CONTINENCY PLAN 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

41. Hazardous Waste Management 41 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. CONTINENCY PLAN 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.

42. Hazardous Waste Management 42 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. AFTER AN INCIDENT 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.

43. Hazardous Waste Management 43 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. EMERGENCY COORDINATOR 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.

44. Hazardous Waste Management 44 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. EMERGENCY COORDINATOR 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.

45. Hazardous Waste Management 45 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. EMERGENCY COORDINATOR 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

46. Hazardous Waste Management 46 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. TRAINING 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

47. Hazardous Waste Management 47 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. TRAINING 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.

48. Hazardous Waste Management 48 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. TRAINING 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.

49. Hazardous Waste Management 49 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. TRAINING RECORDS 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.

50. Hazardous Waste Management 50 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. GENERAL INSPECTION REQUIREMENTS 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.

51. Hazardous Waste Management 51 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. GENERAL INSPECTION REQUIREMENTS INSPECTION LOG FacilityInclusive Dates: From:_________ To: __________ DateInspector’s Name Signature Areas Inspected General Containers Tanks Deficiencies Noted

52. Hazardous Waste Management 52 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. GENERAL INSPECTION REQUIREMENTS DEFICIENCY REPORT Inspector: If a deficiency is noted, please complete the following information, make a copy and report to the Facility Manager. You must verify that corrective actions have been taken. Date of ReportDescription of Deficiency Corrective Action Needed Correction Verified (Date/Initials)

53. Hazardous Waste Management 53 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. GENERAL CHECKLIST Checklist Items Should Include: Structures Safety Equipment Security Equipment Communication Equipment Facility Equipment

54. Hazardous Waste Management 54 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. CONTAINER AND TANK CHECKLISTS Containers Should be Checked For: Integrity Labels Compatibility of Wastes Distance from Fence Line Aisle Space Secondary Containment Tanks Should Have Their Own Checklist

55. Hazardous Waste Management 55 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. EPA’s AUDIT POLICY EPA’s 1995 Audit Policy EPA will not seek gravity-based penalties and will not recommend criminal prosecutions for companies that meet the requirements of the policy. Companies are required: to promptly disclose and correct violations, to prevent recurrence of the violation, and to remedy environmental harm.

56. Hazardous Waste Management 56 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. COMPARISON OF RCRA GENERATOR REQUIREMENTS RequirementCESQGSQGLQG Quantity Limits  100 kg/mo (220.46 lb/mo)  100 kg/mo (220.46 lb/mo) to 1000 kg/mo (2204.62 lb/mo) >1,000 kg/mo (2,204.62 lb/mo) Acute Waste Limits  1 kg/mo (2.20 lb/mo)  1 kg/mo (2.20 lb/mo) None Facility Receiving Waste State approved RCRA, interim status or exempt recycling facility RCRA permitted, interim status, or exempt recycling facility. EPA ID NumberNot Required Required

57. Hazardous Waste Management 57 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. COMPARISON OF RCRA GENERATOR REQUIREMENTS RequirementCESQGSQGLQG Determination whether solid waste is hazardous Yes RCRA Personnel Training Not RequiredBasic Training Required Required Exception ReportNot RequiredRequired within 60 days of HW being accepted by initial transporter Required within 45 days of HW being accepted by initial transporter Biennial ReportNot Required Required

58. Hazardous Waste Management 58 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. COMPARISON OF RCRA GENERATOR REQUIREMENTS RequirementCESQGSQGLQG On-site Accumulation Limits (without permit) 1,000 kg (2,204.62 lb) 6,000 kg (13,227.73 lb) Any quantity Accumulation Time Limits (without permit None180 days (270 if transported more than 200 miles) 90 days * Storage Requirements for Accumulated HW NoneBasic requirements with technical standards for containers. Full compliance with container or tank management Use ManifestsNoYes Contingency Plan No Required

59. Hazardous Waste Management 59 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC.  Remember, You Control Your Facility or Area!  Review Procedures With Them Before Starting the Job!  Ensure They Are Properly Trained!  Determine Their Environmental Compliance Record!  Determine Who Is in Charge of Their People!  Determine How They Will Affect Your Facility’s Environmental Compliance! TIPS FOR USING CONTRACTORS

60. Hazardous Waste Management 60 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. ELEMENTS OF SUCCESSFUL HAZARDOUS WASTE MANAGEMENT 1. DETAILED WRITTEN CONTINGENCY PLAN. 2. DETAILED WRITTEN INSTRUCTIONS ON INSPECTIONS AND THE ACCOMPANYING LOGS AND RECORDS. 3. EXTENSIVE EMPLOYEE TRAINING PROGRAMS 4. PERIODIC REINFORCEMENT OF TRAINING 5. SUFFICIENT DISCIPLINE REGARDING IMPLEMENTATION 6. PERIODIC FOLLOW-UP

61. Hazardous Waste Management 61 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. THE IMPORTANCE OF A CLEAN ENVIRONMENT “I would ask all of us to remember that protecting our environment is about protecting where we live and how we live. Let us join together to protect our health, our economy, and our communities -- so all of us and our children and our grandchildren can enjoy a healthy and a prosperous life.” Carol Browner Former EPA Administrator