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9 th Annual California Unified Program Conference

9 th Annual California Unified Program Conference

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9 th Annual California Unified Program Conference

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  1. 9th Annual California Unified Program Conference Advanced Hazardous Waste Inspector Training 9th Annual California Unified Program Conference

  2. Part IIIHazardous Waste Container &Tank Standards Definitions Pictures Regulations & Guidance documents 9th Annual California Unified Program Conference

  3. Tank Defined • UFC 9.122 Tank is a vessel containing > 60 gals. • 40 CFR §260.10Tank means a stationary device, designed to contain an accumulation of hazardous waste which is constructed primarily of non-earthen materials which provide structural support. • 22 CCR § 66260.10 "Tank" means a stationarydevice, designed to contain an accumulation of hazardous waste which is constructed primarily of non-earthen materials which provide structural support. 9th Annual California Unified Program Conference

  4. Tank System • 40 CFR §260.10Tank system means a hazardous waste storage or treatment tank and its associated ancillary equipment and containment system. • 22 CCR § 66260.10 "Tank system" means a hazardous waste transfer, storage or treatment tank and its associated ancillary equipment and containment system. 9th Annual California Unified Program Conference

  5. Container • 40 CFR §260.10Container means any portable device in which a material is stored, transported, treated, disposed of, or otherwise handled. • 22 CCR §66260.10 "Container" means any device that is open or closed, and portable in which a material can be stored, handled, treated, transported, recycled or disposed of. 9th Annual California Unified Program Conference

  6. A Tank is stationary A Container is portable 9th Annual California Unified Program Conference

  7. Is it a: a. Tank or b. Container? 9th Annual California Unified Program Conference

  8. Is it a: a. Tank or b. Container? 9th Annual California Unified Program Conference

  9. Is it a: a. Tank or b. Container? 9th Annual California Unified Program Conference

  10. Is it a: a. Tank or b. Container? Filter Cake 9th Annual California Unified Program Conference

  11. Is it a: a. Tank or b. Container? 9th Annual California Unified Program Conference

  12. Portable Tank? 9th Annual California Unified Program Conference

  13. Ancillary Equipment • 40 CFR §260.10 reads just like § 66260.10. • 22 CCR § 66260.10 "Ancillary equipment" means any device including, but not limited to, such devices as piping, fittings, flanges, valves and pumps, that is used to distribute, meter or control the flow of hazardous waste from its point of generation to a storage or treatment tank(s), between hazardous waste storage and treatment tanks to a point of disposal onsite, or to a point of shipment for disposal offsite. 9th Annual California Unified Program Conference

  14. Ancillary Equipment? Hazardous Waste Piping 9th Annual California Unified Program Conference

  15. Ancillary Equipment? Green Liquid  9th Annual California Unified Program Conference

  16. Green Liquid pH = 13 9th Annual California Unified Program Conference

  17. Is it a. Ancillary Equipment or b. A Tank? Filter Press Does it Move? 9th Annual California Unified Program Conference

  18. Tanks Standards Apply? Process Tank Process Tank outflow (waste A). non-hazardous Settling Tank Settling tank sludge outflow (waste B), hazardous waste Sludge, Hazardous Waste Heated Drying Tank Which tanks & pipes require a P.E. assessment? Non-hazardous waste water to sewer The blue & burgundy tanks & piping 9th Annual California Unified Program Conference

  19. At what point do the hazardous waste Tank Standards Apply? • The first tank is a process tank. Materials go in, non-hazardous waste flows out. • The settling Tank is a new point of generation. Non-hazardous waste flows in, a hazardous waste flows out. • Does 66261.4(c) Exclusion apply?; the manufacturing tank unit situation. 9th Annual California Unified Program Conference

  20. 22 CCR 66261.4(c) • A hazardous waste which is generated in a product or raw material storage tank, a product or raw material transport vehicle or vessel, a product or raw material pipe line, or in a manufacturing process unit or an associated non-waste-treatment-manufacturing unit, is not subject to regulation under this division until it exits the unit in which it was generated, unless the unit is a surface impoundment, or unless the hazardous waste remains in the unit for more than 90 days after the unit ceases to be operated for manufacturing, or for storage or transportation of product or raw materials. This apples to the hazardous waste generated in these tanks, not the tanks themselves. The tank is subject to Chapter 32, Title 22 (closure) if the unwanted tank exhibits a characteristic of a hazardous waste. 9th Annual California Unified Program Conference

  21. Answer by the CUPA 2005 DTSC Q&A Panel • A process tank sends non-hazardous waste into a settling tank in which liquid and solid fractions separate by gravity. The solids are hazardous and are pumped to a heated drying tank for additional water removal. The water fraction flows from the settling tank directly to the sewer. Which tanks/pipes in this system would require a tank assessment? The piping and pumps that feed the settled solids to the heated drying tank, and the heated drying tank itself would be a tank system and would be subject to tank assessments as provided in CCR, title 22, section 66265.193. The settling tank would not be subject to the tank assessment because the waste as it originally entered the tank was not hazardous, even though a hazardous waste is generated in the tank through settling. 9th Annual California Unified Program Conference

  22. Answer by the CUPA 2005 DTSC Q&A Panel • a. What if (instead of a process tank) this system processes a hazardous waste upstream of the settling tank, and the waste entering the settling tank is non hazardous? • No change in above answer. Even thought the settling tank is at the back end of a treatment system or unit, the definition of “unit” clear says that it is “…combination of tanks or tank systems…located together that are used in sequence to treat or accumulate one or more compatible HAZARDOUS wastestreams.” Once the wastestream was rendered non-hazardous by the upstream treatment system, the settling tank is no longer part of the unit. 9th Annual California Unified Program Conference

  23. Materials Tank that is also used for Waste? • “A related question concerns the applicability of the hazardous waste tank system standards to process transfer equipment normally used for production purposes, but also used to transfer hazardous waste residue to either a NPDES wastewater treatment system or an onsite RCRA treatment/storage facility. Assuming it is removed within 90 days after production or product storage is stopped, the hazardous waste generated within product/raw material process tanks does not become subject to the hazardous waste tank system standards until it exits the unit in which it was generated.” (FAXBACK 13790) 9th Annual California Unified Program Conference

  24. Materials Tank that is also used for Waste: Answer • “The tank system standards apply to ancillary equipment used to handle the hazardous waste during transfer from its point of origin to a hazardous waste storage/treatment tank. We consider the point of exit from the process tank to be the introductory point for the hazardous waste into a hazardous waste tank system. Therefore, any process transfer equipment, even if normally used for production purposes, that is also used to transfer hazardous waste residue during equipment washout/cleanout procedures to a hazardous waste storage/treatment tank, would be considered part of a hazardous waste tank system and thus subject to the standards for such.”(FAXBACK 13790) 9th Annual California Unified Program Conference

  25. Material & Waste Tank System Tanks A, B & C contain material; the piping is used exclusively to transfer the liquid when is no longer useful. Process A Process B Process C No hazardous characteristics Hazardous Waste A A + B A+B+C=D D is a tank; what parts of the system require a P.E. Assessment? What if A is a listed pesticide? D What if D was a 55 gallon drum that was removed when full? 9th Annual California Unified Program Conference

  26. Point of Generation = Start of ancillary equipment • If A is a waste listed for toxicity, then D is a hazardous waste under the mixture rule. D is a tank, so • The point of generation is normally the exit point (pipe) from a process tank. This pipe will be the introductory point for hazardous waste into a hazardous waste tank system, therefore it is ancillary equipment. (FAXBACK 13790) 9th Annual California Unified Program Conference

  27. Answer by CUPA 2005 DTSC Q&A Panel • Three material storage tanks (A,B, and C) are piped together into a fourth tank (D). When materials in tanks A, B, and C are no longer usable, they are released to tank D. The materials in tanks A and B are characteristic hazardous wastes. The material in tank C is non-hazardous. The resultant commingled waste stream found in tank D is non-hazardous. • a. What parts of this system would require a tank assessment? All of the piping leading from tanks A, B, and C to tank D, and tank D itself would be considered a tank system. 9th Annual California Unified Program Conference

  28. Answer by CUPA 2005 DTSC Q&A Panel • b. Does it matter is one of the wastes (say in tank A) is a listed waste instead of a characteristic waste? • Yes. The listing would carry through from tank A through all subsequent tanks and all wastes that the listed waste gets mixed with due to the mixture rule (T22, section 66261.3(a)(2)(E)). The exception to the mixture rule would be if the listed waste was listed only for ignitibility and/or reactivity and the resultant mixture does not exhibit a characteristic. Other specific mixture rule exclusions can be found in 66261.3(a)(2)(F). 9th Annual California Unified Program Conference

  29. Is it a Hazardous Waste Tank System? • It is less clear if D is a container or is not a hazardous waste tank (such as, waste piped directly to the POTW system). • If hazardous waste is not accumulated, stored or treated in a tank then it is not a hazardous waste tank system. So tank standards don’t apply. • The piping is a hazardous waste conveyance system, but • It has to be part of a hazardous waste tank system to be ancillary equipment to a hazardous waste tank. 9th Annual California Unified Program Conference

  30. Tank? Process tank Floor sump 9th Annual California Unified Program Conference

  31. Sumps • Temporary or Emergency Containment Sumps – exempt subject to management procedures, i.e. clean & dry except after emergency. • Secondary-containment Sumps – must meet secondary containment standards • Primary-containment sumps – regulated as tanks (FAXBACK 12442) 9th Annual California Unified Program Conference

  32. Emergency Spill Containment or is it Primary Containment? Berms surrounding tanks area Hazwastes on floor 9th Annual California Unified Program Conference

  33. Emergency Containment? Secondary Containment? Floor Sump 9th Annual California Unified Program Conference

  34. Sumps #1 • “Sumps may present the same potential for leaks and releases as hazardous waste storage and treatment tanks and generally should be subject to the same standards as tanks.” 51 FR 25441 of July 14, 1986. • Sumps for 90-day storage, “Assuming the sumps are made of non-earthen material and have sufficient structural integrity, they would be regulated as tanks.” (faxback 12442) 9th Annual California Unified Program Conference

  35. Sumps #2 • Parking lot test (faxback 12104, 12224) • Surface Impoundment or a Tank? • If freestanding in a parking lot will the unit provide sufficient structural support to hold its contents? • Pass – If it can, it’s a tank • Fail – If it can’t pass, then it is a surface impoundment. A surface impoundment requires RCRA storage permit. 9th Annual California Unified Program Conference

  36. Ancillary Equipment?Secondary Containment? Plating shop floor 9th Annual California Unified Program Conference

  37. Ancillary Equipment? Floor trenches 9th Annual California Unified Program Conference

  38. Floor Drains & Trenches • Building Floor Drains and Trenches used to transfer hazardous wastewater to an in-ground storage tank are ancillary equipment. (FAXBACK 12829, 13653) • 22 CCR 66265.193(f) “Ancillary equipment shall be provided with full secondary containment... Except for” • Components inspected daily, e.g. above ground piping 9th Annual California Unified Program Conference

  39. Joe’s Plating Shop Elevated grate Or “catwalk” Is the sump in the floor a tank? Is the concrete floor ancillary equipment? 9th Annual California Unified Program Conference

  40. Is it a hazardous waste tank? • Is the drag-out from a plating shop a hazardous waste? • Yes • Is the drag-out routinely generated? • Yes • “Generally speaking, any tank system into which hazardous waste is routinely and systematically introduced, regardless of frequency or duration of storage, is not considered either a temporary tank or part of the secondary containment system and therefore must be provided with secondary containment (see 51 FR 25422; July 14, 1986).” Re:OSWER Directive 9483.00-3 9th Annual California Unified Program Conference

  41. What if it’s a spill? • “If cleanup activities do not begin promptly, the spill is considered a land disposal site subject to permitting requirements. …Extended responses which are not judged to be immediate in nature may result in: (1) A modification to the facility’s contingency plan; (2) An enforcement action for an inadequate contingency plan or permit violations; or (3) Enforcement action for illegal disposal.” FAXBACK 12748 9th Annual California Unified Program Conference

  42. How about a spill into secondary containment? Secondary containment for a hazardous waste tank system, that meets tank standards? Then… • §66265.196. Response to Leaks or Spills and Disposition of Leaking or Unfit-for-Use Tank Systems. • A tank system or secondary containment system from which there has been a leak or spill, or which is unfit for use, shall be removed from service immediately, and the owner or operator shall satisfy the following requirements: 9th Annual California Unified Program Conference

  43. §66265.196 • (c) Removal of waste from tank system or secondary containment system. • (1) If the release was from the tank system, the owner or operator shall, within 24 hours after detection of the leak or, if the owner or operator demonstrates that that is not possible, at the earliest practicable time remove as much of the waste as is necessary to prevent further release of hazardous waste to the environment and to allow inspection and repair of the tank system to be performed. • (2) If the release was to a secondary containment system, all released materials shall be removed within 24 hours or in as timely a manner as is possible to prevent harm to human health and the environment. 9th Annual California Unified Program Conference

  44. Wet Floors: Is the floor a regulated tank unit? They are a problem 9th Annual California Unified Program Conference

  45. Big hole in floor beneath acid tank Acid soln. with copper 9th Annual California Unified Program Conference

  46. Deteriorated floor below metal finishing tank Hazwastes 9th Annual California Unified Program Conference

  47. Floor trench used at metal finishing process room Trench 3’ depth 9th Annual California Unified Program Conference

  48. Deteriorated floor underneath metal finishing tanks 9th Annual California Unified Program Conference

  49. State DTSC recent enforcement news December 8, 2005 enforcement settlement: The California Department of Toxic Substances Control (DTSC) announced it has reached a $200,000 settlement with Ultima Circuits, LLC for hazardous waste violations at its facility located at 4361 Pell Drive in Sacramento. DTSC’s Weblink to read full consent order….. http://www.dtsc.ca.gov/HazardousWaste/Projects/upload/ULTIMA_ENF_CO.pdf cont.. 9th Annual California Unified Program Conference

  50. Ultima Circuits recent enforcement case • The settlement stems from violations observed by DTSC inspectors on 1/7/04, & 3/9/05. The violations were: • Failing to provide secondary containment for eight hazardous waste treatment tanks • Discharging hazardous waste directly onto the floor of the facility, where waste then flowed into an UST that lacked secondary containment • Failing to prepare a written assessment, certified by an independent, registered professional engineer, for hazardous waste treatment tank systems, as well as the floor used as a hazardous waste collection tank. Ultima Circuits has ceased using the facility floor as a hazardous waste tank. 9th Annual California Unified Program Conference