Managing Hazardous Waste

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Lesson 4

• Managing Hazardous Waste

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Lesson 4 Objectives

• Be able to identify waste streams generated by
  the KSARNG.
• Understand generator status.
• Learn how to set up waste accumulation areas.
• Be able to select, prepare and label containers.
• Know how to add waste to containers.

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Lesson 4 Objectives - continued

• Understand proper turn-in procedures for
  hazardous materials and waste.
• Understand proper procedures for transporting
  hazardous materials and waste.
• Learn to use Waste Fact Sheets.

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Unneeded HM vs. Waste

• Unneeded HM (Excess)
• No longer needed by your facility
• Still good for its original purpose
• Container is in good condition
• Less stringent management

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Unneeded HM vs. Waste

• Waste
• Whats left after chemicals/materials are used?
• Spent light bulbs, batteries, solvents,
  paints/thinners, etc.
• Used oil and antifreeze
• Materials that are waste like (abandoned)

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Types of Waste

• Solid Waste
• Non-hazardous Waste
• Hazardous Waste
• Universal Waste
• Used Oil
• Non-RCRA Regulated
• Waste that is not specifically regulated under
  RCRA, however the waste is regulated
• Asbestos
• PCBs

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Solid Waste

• Any discarded material that is abandoned,
  recycled, or inherently waste-like
• Includes solids, semi-solids, sludges, liquids,
  or contained gaseous materials
• Excludes household waste, domestic sewage, and
  industrial wastewater discharges

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Non-hazardous Waste

• Do not dispose of liquids in dumpster
• Always contact IHWM to determine proper disposal
  procedures

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Common KSARNG Non-hazardous Waste Streams

• Batteries
• Alkaline
• Petroleum Products
• GAA
• Spill Residue and Debris
• Not contaminated with a Hazardous Waste

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Hazardous Waste

• Must first be a solid waste
• Specifically listed by the EPA
• F, P, U, or K
• Characteristically hazardous
• Ignitable, Corrosive, Reactive, Toxic
• Determined by
• Knowledge of generator (using MSDSs and generator
  processes)
• Laboratory analyses or
• Listed in APCEC Reg. 23, Part 261, Subpart D

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Common KSARNG Hazardous Waste Streams

• Chemical Defense Equipment
• Detector Kits M256
• Decontaminating Kit M258
• Paint/Paint Related Material
• Thinner Dope/Laquer
• Polyurethane Coating
• Petroleum Products
• Contaminated (not off-spec)
• Solvents
• PD 680

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Universal Waste

• Hazardous wastes with less stringent management
  standards
• Does not count against accumulation totals

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Common KSARNG Universal Waste Streams

• Batteries
• Lithium
• NiCad
• Magnesium
• Light Tubes
• Mercury Containing

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Used Oil

• Any oil, whether refined from crude oil or
  synthetically produced that has been used and is
  therefore contaminated with physical or chemical
  impurities
• KSARNG utilizes a re-refined oil contract to
  dispose of used oil and purchase new oil (Safety
  Kleen)

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Re-refined Oil Contract

• DLA Defense Supply Center has a contract with
  Safety Kleen (SK)
• No application required
• Will pick up 120 of used oil purchased
  throughout the fiscal year
• Place pick-up orders through DoD EMALL by calling
  DSN 661-7766 or online at www.emall.dla.mil or
• If you know your SK vendor you can contact them
  directly
• 55-gallon minimum
• Inform SK that it is through the DLA Closed-loop
  program

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Re-refined Oil Contract

• Used oil is tested at pick-up
• Automatic rejects include
• Resin
• Water soluble compounds
• Highly aromatic oils/solvents
• Oily sludge
• Oils high in antifreeze (small amounts accepted)
• Water content greater than 15
• Oils mixed with Hazardous Waste

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Non-RCRA Regulated

• Waste that is not specifically regulated under
  RCRA, however the waste is regulated
• Ex lead-based paint, asbestos, and PCBs are
  regulated under the Toxic Substance Control Act
  and Radioactive waste is regulated by the Nuclear
  Regulatory Commission

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Hazardous Waste Accumulation Limits
Generator Classification Pounds of Hazardous Waste Generated Monthly How Long Waste Can Be Accumulated
Small Quantity lt55 180
Kansas gt55 - lt2200 180
EPA gt2200 90
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Accumulating Hazardous Waste

• Satellite Accumulation Point (SAP)
• Hazardous Waste Accumulation Areas (HWAA)

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Satellite Accumulation Point

• ONLY Kansas or EPA generators can establish a
  Satellite Accumulation Point (SAP)
• ONLY 55 gallons of hazardous waste can be
  accumulated in a SAP container or 1 quart of
  P-listed acutely hazardous waste
• SAPs are located at or near the process
  generating hazardous waste
• SAPs must be under the control of the operator
  (one person)

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Satellite Accumulation Point

• SAP containers must be labeled as hazardous waste
  w/ content
• Accumulation start date is necessary once the
  container is full
• Must be moved to HWAA within 72 hours of marking
  the container with an ASD
• Contact the IHWPM for approval and guidance for
  establishing and maintaining a SAP

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HWAA Requirements

• Secure well ventilated area
• Secondary containment for liquid wastes
• Spill response kit and fire extinguisher nearby
• HWAA warning signs posted
• Inspect weekly!

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Weekly Inspection Log
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Selecting, Preparing and Labeling Containers

• KSARNG utilizes Waste Fact Sheets
• Waste Fact Sheets are step-by-step instructions
  on how to manage a waste stream from start to
  finish
• Waste Fact Sheets are specific to each KSARNG
  waste stream

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KSARNG Waste Fact Sheet
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Waste Fact Sheet

• Step 1. Select an Approved Container
• Step 2. Mark and Label the Container With the
  Following Information
• Step 3. Put Waste in the Container
• Step 4. Accumulate Waste in an Approved Location
• Step 5. Turn-in Procedures

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Select an Approved Container

• Large quantities of liquid typically go in
  30-gallon or larger non-removable head drums
• Large quantities of solid materials typically go
  in 30-gallon or larger removable head drums
• Batteries typically go in a plastic screw top pale

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Mark and Label the Container

• Containers should be labeled in accordance with
  the Waste Fact Sheets
• If you do not have the appropriate sticker,
  writing on the container with a permanent marker
  or paint pen is sufficient

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Put Waste in the Container

• Check the MSDS for the material and don the
  proper PPE before adding waste to the container
• Always add from a smaller container to a larger
  container
• Ensure that lids and bungs remain closed unless
  adding or removing waste

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Accumulate Waste in an Approved Location

• Accumulate waste in the designated Hazardous
  Waste Accumulation Area(s)

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Turn-in Procedures

• Turn in waste in accordance with the Turn-in
  Waste Fact Sheet
• Personnel should make every effort to provide all
  of the information required

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Transporting Hazardous Materials and Waste

• EPA and KS generators are not authorized to
  transport hazardous waste over public roadways
• Small Quantity Generators can transport hazardous
  waste to a supporting FMS as long as it is not
  over 55 lbs and meets all DOT requirements
• Contact DOFE-E to insure that all requirements
  have been met before transport

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Practical Exercise

• Setting Up Accumulation Areas

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Practical Exercise

• Solid Waste Survey

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Practical Exercise

• Using Waste Fact Sheets

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Questions?