HAZARDOUS WASTE TRAINING NJ Solid Waste Management Act & Resource Conservation and Recovery Act
The Regulations • 1976 Resource Conservation and Recovery Act (RCRA) • 1984 Hazardous and Solid Waste Amendments • Federal Standards 40CFR Parts 260 to 299 • 1999 NJ Solid Waste Management Act • State Standard NJAC 7:26G
Major Goals of RCRA • Reduce wastes and provide for conservation of resources. • Protect human health and the environment from potential harm caused by improper waste disposal and from dangers posed by leaking underground storage tanks. • Management of Hazardous Waste from “Cradle-to-Grave”
“Solid Waste” • Anything no longer needed or wanted • Regulatory term for garbage, trash or refuse • Can be liquids, contained gases or solids • Hazardous Wastes are a specific category of Solid Waste
Hazardous Waste Generators • Obtain EPA generator ID number • Determine if waste is hazardous • Adhere to land disposal restrictions • Manifest waste shipments • Designate a transporter and a Treatment, Storage and Disposal Facility (TSDF) that each possess an EPA ID number • Prepare and implement a contingency plan • Perform record keeping and reporting requirements • Pay all applicable fees
Training Requirements • As documented in NJAC7:26-9.4(g) and 40CFR263.34(d)(5)(iii) • Hazardous waste generators must ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures, relevant to their responsibilities during normal facility operations and emergencies. • Initial training with annual review
A Hazardous Waste • Any solid, liquid, semi-solid or contained gaseous material that is capable of posing a substantial present or potential hazard to human health, living organisms or the environment when improperly treated, stored, transported, disposed of or otherwise managed. • Failure to make a waste determination is a serious and common breach of the RCRA regulations
How to Determine if a Waste is Hazardous 1 • Specifically Listed Materials F-List: non-specific sources (click on 40 CFR §261.31 athttp://www.epa.gov/epaoswer/osw/hazwaste.htm) K-List: specific sources (click on 40 CFR §261.32 at http://www.epa.gov/epaoswer/osw/hazwaste.htm) P-List: acute hazardous waste (click on 40 CFR §261.33at (http://www.epa.gov/epaoswer/osw/hazwaste.htm U-List: toxic waste (click on 40 CFR §261.33and scroll past the P list to the U list at http://www.epa.gov/epaoswer/osw/hazwaste.htm C-List: hazardous constituents (click on 40 CFR Part 261 Subpart C at http://www.epa.gov/epaoswer/osw/hazwaste.htm) X-List: State list from non-specific sources
How to Determine if a Waste is Hazardous 2 • Has been found to be fatal to humans in low doses. • In the absence of human toxicity data it has been shown in studies to: • Oral LD50 (rat): less than 50mg/kg • Inhalation LC50 (rat): less than 2 mg/L • Dermal LD50 (rabbit): less than 200 mg/kg • Capable of causing or significantly contributing to an increase in serious irreversible or incapacitating reversible, illness.
How to Determine if a Waste is Hazardous 3 • Exhibit a Hazardous Characteristic (see Training Documentation for more information and definitions) • Ignitable • Corrosive • Reactive • Toxic (D-List) • If you need help send an e-mail to D. Smith or J. Mazzocca
HazardousWaste Generator Categories Note: 1 kg of acute hazardous waste, 100 kg residue or clean up of acute waste puts site into LQG status.
Actual Hazardous Waste Generated
New Waste Inventory Log
Satellite Accumulation Area • Area must be at or near point of generation and under the control of the operator • May have many SAA’s on Campus • Less than 55 gallon hazardous waste or 1 quart acutely hazardous waste (P-list) • Moved to storage area within 3 days of filling
Satellite Accumulation Area • Incompatible waste must be segregated • Containers must be compatible with waste, in good condition, kept closed, managed to prevent rupture or leak, have secondary containment • Clearly marked as “Hazardous Waste” • Label with Contents & Concentration • Clearly marked start date and date filled • Visible for inspection
On-Site Storage • Less than: 180 days, 6,000 kg • Segregate incompatible waste • Store according to hazard classification • Minimize risk of explosion, release into the environment • Must use secondary containment • Use “Hazardous Waste Inventory Log” • Must inspect weekly; retain records for 3 years!
Example Hazardous Waste Label
HAZARDOUS WASTE CONTAINER/STORAGE AREA INSPECTION LOG Location 1Inspections must be performed weekly and the Inspection Log must be retained for a period of three years. 2If all conditions are OK place a check in that section. If conditions were not OK make a note in that section and describe corrective action taken (use additional sheets as necessary). 3Consult MSDS for proper storage conditions. 4Stockton is currently a SQG; hazardous waste must not be stored for longer than 180 days or 6 months 5Containment system must have sufficient capacity to contain 10% of the volume of containers or the volume of the largest container, whichever is greater.
Container Rules NJAC 7:26-8.4 • Container or liner that held hazardous waste is empty if: • All waste have been removed that can be removed using practices commonly employed to remove materials from that type of container (pouring, pumping and aspirating) • No more than 2.5 cm (one inch) of residue remain on the bottom
Container Rules NJAC 7:26-8.4 • Container or liner that held hazardous waste that is a compressed gas is empty when the pressure in the container approaches atmospheric.
Container Rules NJAC 7:26-8.4 • Container or liner that held an acute hazardous waste is empty if: • All waste have been removed that can be removed using practices commonly employed to remove materials from that type of container (pouring, pumping and aspirating) • No more than 2.5 cm (one inch) of residue remain on the bottom • The container or liner has been triple rinsed using a solvent capable of removing the acutely hazardous waste (rinsing solvents are acutely hazardous waste!)
Container Rules NJAC 7:26-8.4 • Container or liner that held an PCB hazardous waste is empty if: • All waste have been removed that can be removed using practices commonly employed to remove materials from that type of container (pouring, pumping and aspirating) • No more than 2.5 cm (one inch) of residue remain on the bottom • The container or liner has been triple rinsed in accordance with 40CFR761 with a suitable solvent containing 50 ppm PCB’s or less, the solubility of PCB’s in the solvent being five percent or more by weight
EPA/NJ Universal Waste Rule • Separate Category • low-toxicity, high volume waste • Streamlined management program • Reduce regulatory burden, longer storage, reduced recordkeeping • Primary Objective – encourage recycling
EPA/NJ Universal Waste Rule • Categories of Universal Waste • Batteries • Pesticides • Lamps • Mercury-containing equipment • Plant Management coordinates disposal and regulatory compliance of Universal Waste on Campus
Universal Waste Generator Categories
Used Oil 40CFR279 • Any oil that has been refined from crude oil, or any synthetic oil, that has been used and as a result of such use is contaminated by physical or chemical impurities
Used Oil “Management Standards” • Safe handling • Label all containers and tanks • Keep in good condition • Do not mix with hazardous waste • Maximize recycling • Minimize disposal
Waste Minimization Program • SQG-must make a “good faith effort” • Substitution of less hazardous materials • Recycle • Reduce scale of use • Controlled inventory/avoid duplication • Purchase only what you need
Contingency Plan - 265 Subpart D • A document setting out an organized, planned, and coordinated course of action to be followed in case of a fire, explosion, or discharge of hazardous waste or hazardous waste constituents which could threaten human health or the environment. • Not required for SQG • College has “Emergency Operations Plan”
Preparedness and Prevention Facilities must be maintained and operated to minimize the possibility of fire, explosion, or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents to the air, soil, or surface water which could threaten human health or the environment
Required Equipment • Alarm system-emergency instruction • Telephone/radio to call for emergency assistance • Portable fire extinguishers, fire control, spill control and decontamination equipment • Water with adequate volume and pressure to supply emergency equipment • Must be tested and maintained to assure operational for emergencies
Emergency Procedures • Emergency Coordinator on-site or on-call • Post next to telephone • Name and telephone number of emergency coordinator (Campus Police dial 911) • Location of fire extinguishers, spill control material and fire alarm • Telephone number of fire department, unless there is a direct line. (Campus Police dial 911) • Ensure employees are trained to handle hazardous waste and emergencies. • Facility must properly respond to and report an emergency
Emergency Procedures • Protection of life and health • Protection of property and environment • Evacuate Building • Notify Campus Police x911 • If safe, if trained, begin control measures
Emergency Response • First Responder Awareness Level • Likely to witness or discover release • Protect yourself • Call for trained personnel • Secure area • First Responder Operations Level • Respond for purpose of protecting people, property and the environment from the effects of the release. Respond from a safe distance and keep from spreading.
Hazardous Waste Emergency Operating Procedures Number 6901 • Purpose: To ensure that all facility personnel are able to respond effectively to emergencies by familiarizing them with emergency procedures, emergency equipment and emergency systems. • PPE, fire extinguishers, respirators, alarm systems
Building Evacuation - Procedure 6921 • Audible bell/horn and Visual strobe light • Exit through the nearest door • Assemble in parking lot • Evacuees bring valuables and outside garments • Last person exiting area should lock doors • Failure to evacuate is a violation of NJ Statute and violators are subject to penalties. • Elevators should not be used during evacuation • Signal to return given by Campus Police or Fire Official.
Laboratory Emergency Shutdown Procedure • Stop Activities • Close Fume Hoods • Cap chemical containers • Turn off electrical devices not on generators • Turn off gas cylinders • Not on purge of moisture sensitive instrumentation or reactive materials • Turn off Bunsen burners • Vent cryogenic liquids • Lock Laboratory
Spills and Emergencies 2004-8 • Small quantity liquids less than 2.5 gallons • Confine • Neutralizing Agent or Absorbent Mixtures • Let evaporate, if volatile turn off ignition and heat sources • Clean up and dispose of according to hazard classification • Small quantity solids • Sweep low toxicity substances into dust pan and place in solid waste container for disposal. Staff to determine hazard classification and disposal procedures.
Large Quantity Spills • Evacuate area • Call Campus Police x911 • Call Director of Plant Management x4221 • Call Director of Academic Laboratories x4490 • F-Wing assemble in courtyard between D, E and F wings. • A&S assemble in front courtyard • Lab Director will notify appropriate Regulatory Agencies
Hazardous Waste Disposal • Every Budget Unit Manager is responsible for the safe storage and disposal of the hazardous waste generated in their unit! • Watch the amounts you generate in a given month and let us know if you are approaching the SQG limits!!!! • Every Budget Unit Manager is responsible for ensuring their staff are fully trained! • All employees working with hazardous chemicals must be familiar with lawful disposal procedures!
Penalties for Violation of Rules • ~460 Line Item Penalties $300-$50,000 • Failure to properly manage waste containers - $2,000 • Failure to clearly mark containers with accumulation start date or make visible for inspection - $5,000 • Failure to mark container with words “Hazardous Waste” - $1,000 • Failure of facility owner or operator to provide required classroom or on-the-job training for facility personnel. - $2,000
