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Smithfield Foods Environmental Conference Omaha, NE September 14, 2010

Smithfield Foods Environmental Conference Omaha, NE September 14, 2010. Hazardous Waste Management. Characteristic Hazardous Waste. Ignitable – (paints, degreasers, solvents), creates a fire hazard: - liquid with a flash point of <140 o F;

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Smithfield Foods Environmental Conference Omaha, NE September 14, 2010

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  1. Smithfield Foods Environmental ConferenceOmaha, NESeptember 14, 2010 Hazardous Waste Management

  2. Characteristic Hazardous Waste • Ignitable– (paints, degreasers, solvents), creates a fire hazard: - liquid with a flash point of <140 oF; - solid if capable of causing fire through friction, absorption of moisture, or spontaneous chemical change and when ignited burns so vigorously and persistently that it creates a hazard; - compressed ignitable gas Reference: 40 CFR 261.20 – 261.24

  3. Characteristic Hazardous Waste • Corrosive– (rust removers, battery acids) extracts and solubilizes toxic contaminants such as heavy metals from other wastes, - aqueous with a pH<2.0 or pH>12.5 Reference: 40 CFR 261.20 – 261.24

  4. Characteristic Hazardous Waste • Reactive– (cyanides or sulfides) - Normally unstable and readily undergoes violent change - Reacts violently with water - Forms potentially explosive mixtures with water - Generates toxic gases/vapors/fumes when mixed with water - Is a cyanide or sulfide bearing waste - Is capable of explosive reaction if placed under heat or pressure Reference: 40 CFR 261.20 – 261.24

  5. Characteristic Hazardous Waste • Toxic– (cadmium, mercury, lead) harmful or fatal when ingested or absorbed or leaches toxic chemicals into the soil or ground when land filled – test for toxicity through Toxic Characteristic Leaching Procedure (TCLP) above regulatory level (MEK >200 mg/L) Reference: 40 CFR 261.20 – 261.24

  6. Listed Hazardous Waste • Wastes listed in 40 CFR 261 Subpart D are considered hazardous if they appear on one of four lists: • F – nonspecific sources – spend solvent wastes (F001 – F039, F003 = Acetone, F005 = MEK) • K – specific sources (Not Applicable to Our Industry) • U & P – discarded or off-spec chemical products, container residue, unused pesticides (Not Generally Applicable to Our Industry) • There are currently more than 500 wastes listed because they are known to be harmful to human health and the environment. Reference: 40 CFR 261.30 – 261.35

  7. Generator Status • CESQG – Conditionally Exempt Small Quantity Generator (<220 lbs/month and <2.2 lbs/month of acutely hazardous waste) • SQG – Small Quantity Generator (>220 lbs/month, but <2,200 lbs/month and <2.2 lbs/month of acutely hazardous waste) • LQG – Large Quantity Generator (>2,200 lbs/month and >2.2 lbs/month of acutely hazardous waste)

  8. Hazardous Waste Determination • To identify if a solid waste is a hazardous waste • Applicable to all Smithfield Foods operating facilities • Must be documented and readily available in case of inspection • Must be updated upon identification of any new waste stream • Include: crushed fluorescent bulbs; paint waste; spent COD test waste; broken mercury thermometers; aerosol can liquid waste; lab waste/spent reagents; spent acids and bases; spent solvents for parts washing or cleaning printer heads; and shop rags/ paper towels with solvents (MEK, methanol, acetone)

  9. Aerosol Can Punching System • Aerosol can waste is generally flammable, so it needs to be handled as a hazardous waste • Ensure you have (and are using) an aerosol can punching system • Ensure this is on your hazardous waste determination list

  10. CESQG Requirements • Identify Hazardous Wastes and Document Determination • Update Determination Spreadsheet as necessary • Keep Records of Hazardous Waste Shipments to ensure your facility stays below SQG thresholds • Smithfield Foods (Not Federal) Requirements: - Properly label and store hazardous waste - Properly disposal of hazardous waste

  11. SQG Requirements • Identify Hazardous Wastes and Document Determination • Update Determination Spreadsheet as necessary • Obtain EPA Identification Number • Complete and submit a copy of EPA Form 8700-12, Notification of Hazardous Waste Activity • Follow Sign/Labeling, Storage and Disposal and Recordkeeping Requirements

  12. Satellite Storage Requirements • Allowed one 55 gallon drum of hazardous waste at a satellite storage area with restricted access, >50 feet from property line • Don’t date the drum of hazardous waste until the drum is full • Dispose of the drum before it is full so that it never has to be dated • Containers must be compatible with the hazardous waste being stored (prevent corrosion/reactivity) • Be kept closed during storage, except when adding or removing waste • Be kept in good condition • Inspect storage containers regularly to identify leaks and/or signs of deterioration

  13. Sign/Labeling Requirements • Label drum with: Flammable; Hazardous Waste; Contents (such as Aerosol Can Liquid); Facility Name; Address; EPA ID Number; EPA Waste Code • Label location: Hazardous Waste Satellite Storage Area • Post a sign: Location of the nearest telephone (which is accessible 24 hours/day) is… • Post a sign: No Smoking • Post a sign: Authorized Personnel Only • At the nearest telephone, post a sign with emergency phone numbers, location of nearest spill kit, and nearest fire extinguisher

  14. Accumulation Area Requirements • If drum in a satellite storage area becomes full, date it and move to an accumulation area within 3 days • Label Area: Hazardous Waste Accumulation Area • All sign/label and storage requirements previously mentioned apply

  15. Disposal and Record Keeping • Ensure your waste disposal firm is fully licensed to dispose of hazardous waste • Package, label and mark your shipment • Prepare a hazardous waste manifest • Include a notice and certification with the first waste shipment • Retain manifests for life

  16. LQG Requirements • LQG: >2,200 lbs/month generated • Subject to full Hazardous Waste Rule • Determine amounts of hazardous waste generated • Retain an EPA Identification Number • Prepare wastes for shipments and complete manifests • Accumulate for no more than 90 days • Prepare a biennial report (keep copies for 5 years) • Monitor air emissions (if applicable)

  17. Training Requirements • Annual training is required for all employees who handle or work around hazardous waste and include: - identification of hazardous waste streams - proper labeling and storage requirements - safe handling practices/ emergency response procedures - inspection and recordkeeping requirements - proper housekeeping Keep training records for 3 years

  18. Mixture Rule • Anything mixed with a hazardous waste becomes a hazardous waste – so don’t mix. • Mixing any material with a hazardous waste: - will increase your hazardous waste disposal costs; - can lead to more complex and expensive clean-ups; and - could lead to an unsafe work environment.

  19. Waste Minimization • Switch from solvent based to aqueous based parts cleaning fluid • Safely store hazardous chemicals to avoid release/spills • Review processes/procedures to minimize hazardous waste generation

  20. Rags with Solvent/Ink Waste • If you are a CESQG, you just need to characterize your hazardous waste and be able to document that you generate less than 220 lbs of hazardous waste per month (even assuming all rags with solvent on them are hazardous).  If you remain CESQG, all rags with solvent on them can go in the trash. • If you are a SQG or greater and you use solvents (MEK, or acetone) for solvent purposes to clean printer heads – let it dry so that you do not create a hazardous waste with rags.  If you do clean up with rags, then it’s an F listed hazardous waste and needs to be managed/disposed of as such. • If you are a SQG or greater and you clean up the ink off printer heads with a rag (without the use of any solvent to remove the ink), it’s not a listed waste because the solvent in the ink is not used for solvent purposes.  The characteristic of ignitability is not going to catch you, but if your ink contains MEK, then you probably should test it for MEK TCLP and if <200 mg/L, it’s not a hazardous waste.  Note that if your ink contains acetone or methanol (just not MEK), then you don’t have to worry about toxicity characteristics.

  21. Clear as Mud? • Call your Subsidiary Environmental Coordinator or Smithfield Corporate Environmental with questions • Remember that there are worker safety issues with solvents, inks, and other flammables that could pose a fire protection or safety hazard regardless of the RCRA implications

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