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VI Department of Planning and Natural Resources Workshop

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Title: VI Department of Planning and Natural Resources Workshop


1
Applicability of EPA Standards to Transporters of
Hazardous Waste Materials
  • Eduardo R. González, PE, DEE, MBA, REM, CEA
  • Caribbean Environmental Protection Division

2
Regulated EPA Facility
3
Background
  • Environmental Protection Agency (EPA)
  • Enacted to ensure safe management of hazardous
    waste transporters which play an integral role in
    the cradle-to-grave hazardous waste management
    regulations.
  • Section 3003 of the Resource Conservation and
    Recovery Act (RCRA) required EPA to promulgate
    standards for hazardous waste transporters that
    would be protective of human health and the
    environment.
  • EPA adopted certain Department of Transportation
    (DOT) regulations pertaining to the transport of
    hazardous waste (49 CFR Parts 100-185).
  • RCRA transporter regulations are found in 40 CFR
    Part 263.
  • These regulations establish management standards
    for the off-site transportation of hazardous
    wastes by highway, rail, air, or water.
  • Department of Transportation (DOT)
  • Primary purpose is to protect the public and
    transportation equipment measures to protect the
    public also protect employees.
  • Covers transportation by aircraft, rail, vessels,
    and motor vehicles.
  • The Department of Transportation (DOT) was
    created to administer and enforce transportation
    regulations.

4
Background
  • Occupational Safety Health Administration
  • Enacted to ensure safe and healthful working
    conditions for every working man and woman.
  • Covers every employer engaged in business
    affecting interstate commerce who has one or more
    employees.
  • OSHA was created to promulgate and enforce safety
    and health standards.
  • The Federal Highway Administration (FHA)
  • Enforces DOT regulations applicable to motor
    carriers, shippers by highway, and manufacturers
    of cargo tanks through the Office of Motor
    Carrier Field Operations. Also enforces the
    Hazardous Materials Regulations (49 CFR 171-180).
  • Administers Federal motor carrier safety laws (49
    CFR 390-397).
  • The Federal Railroad Administration (FRA)
  • Enforces DOT regulations applicable to rail
    carriers, shippers by rail, and manufacturers of
    tank cars. Also enforces the Hazardous Materials
    Regulations (49 CFR 171-180).
  • Administers Federal railroad safety laws (49 CFR
    Parts 200-299).
  • Issues orders to address hazards caused by the
    transportation of hazardous materials.

5
Laws Affecting The Production And Use Of A Product
6
Energy Usage In US
Changes in US Energy Consumption
Cunningham and Saigo, 1995
US Department of Energy, 1995
7
Energy Flow In The U.S., 1995
(US Department of Energy, 1996)
8
World Proven Oil Reserves, 1991
(World Resources Institute, 1991)
9
Puerto Rico 2006
  • Reported Disposal or Other Releases and Other
    Waste Management Activities (in pounds) Toxic
    Release Inventory
  • Total On-site Disposal to Class
  • Underground Injection
  • Wells, RCRA Subtitle C
  • Landfills, and other
  • Landfills
  •  Class I Wells
    0
  •  RCRA Subtitle C Landfills 300 
  • Other Landfills
    30,415
  • SubTotal
    30,715
  • Other On-site Disposal or
  • Other Releases
  • Fugitive Air Emissions 691,018
  • Point Source Air Emissions 5,694,393
  • Surface Water Discharges 16,153 
  • Class II-V Wells
  • Land Treatment
  • RCRA Subtitle C Surface
  • Impoundment

10
Hazardous Materials Transportation Act
  • Principal statute governing the
    transportation of hazardous materials. Regulates
    packaging and labeling, requires transportation
    manifests, establishes driver and vehicle
    standards, and imposes emergency response and
    reporting requirements. 1990 amendments (HMTA)
    establish hazardous materials employee training
    requirements, registration and permitting of
    certain transporters, and financial
    responsibility requirements

11
EPA DOT Requirements
Waste Classification
Any material that meets the

49 CFR 171.8
definition of one or more DOT
49 CFR 173
hazard classes
Names published by DOT. Order of
Proper Shipping
priority is chemical name, chemical
group, end use, generic end use,
Name
and hazard class
49 CFR 172.101
49 CFR 173 Column 8 of Table
172.101 provides packaging
Selection of Packaging
requirements for specific types of
49 CFR 173, 178 and 179
materials Column 7 includes special
packaging requirements
Marking and Labeling
Labels provide an immediate indication
49 CFR 172.300 and
of hazards and precautions markings
49 CFR 172.400
include detailed information
Shipping papers may be in the form of a
Shipping Papers
bill of lading, shipping order, or
hazardous waste manifest provided
49 CFR 172.200
requirements of 40 CFR are met
Placards indicate the hazards of the
material in the vehicle with few
Placarding
exceptions, vehicles requiring placards
49 CFR 172.500
must affix two on each side, one on
front and one on back
Emergency response information must
Emergency
be provided and maintained during any
Preparedness
phase of transportation including loading
49 CFR 172.600
and storage
12
Transportation of Hazardous Waste
  • DOTs Hazardous Materials Regulations (49 CFR
    171-180)
  • Contain training requirements for all hazardous
    materials employees regarding the safe loading,
    unloading, handling, storing, and transporting of
    hazardous materials, and also regarding emergency
    preparedness.
  • Do not require the hazmat employee to engage in
    actual emergency response activities.
  • Contain information requirements for hazardous
    materials emergency response.
  • DOTs Hazardous Materials Emergency Response
    Requirements
  • Keep emergency response information accessible at
    all times,
  • Provide an emergency response telephone number,
  • Require the operator to contact the carrier in
    the event of a hazardous materials incident, and
  • Report the incident to the proper authorities in
    accordance with 49 CFR 171.15 and 171.16.

13
Transportation of Hazardous Waste (cont.)
  • Definitions from DOT s Hazardous Materials
    Regulations
  • HAZMAT employer is a person who uses its
    employees in connection with
  • transportation in commerce
  • causing hazmat to be transported or shipped in
    commerce or
  • representing, marking, certifying, selling,
    offering, reconditioning, testing, repairing, or
    modifying packaging's as qualified for use in the
    transportation of hazmat.
  • HAZMAT employee is a person who is employed by a
    hazmat employer and directly affects hazmat
    transportation safety who
  • loads, unloads, or handles hazmat
  • tests, reconditions, repairs, modifies, marks, or
    otherwise represents packagings as qualified for
    use in the transport of hazmat
  • prepares hazmat for transportation or
  • operates a vehicle used to transport hazmat.

14
Applicability of HAZWOPER to Hazardous Waste
Transportation
  • Each carrier who transports hazardous materials
    will be required to comply with OSHAs HAZWOPER
    standard, 29 CFR 1910.120, if any of the
    following conditions are met
  • Employees are required to drive onto uncontrolled
    hazardous waste sites .
  • Employees are required to enter EPA regulated
    treatment, storage, and disposal facilities.
  • Employees are required to respond to hazardous
    waste emergencies.
  • Employees are required to handle, inspect, stop
    or clean up leaks, etc ,
  • in or on a loaded transporter.

15
Applicability of HAZWOPER to Hazardous Waste
Transportation (cont.)
  • If employees are required to drive onto
    uncontrolled hazardous waste sites
  • Employees must receive the minimum training
    required by 29 CFR 1910.120(e).
  • 24 hours off-site instruction and one day actual
    field experience under the direct supervision of
    a trained, experienced supervisor.
  • 8 hours of annual refresher training.
  • Employees who enter contaminated areas may need
    to comply with the
  • Site-specific safety and health plan required by
    29 CFR 1910.120(b)(4).
  • Decontamination procedures established for the
    site required by 29 CFR 1910.120(k).

16
Applicability of HAZWOPER to Hazardous Waste
Transportation (cont.)
  • If employees are required to enter EPA regulated
    treatment, storage, and disposal facilities
  • Employees must receive the minimum training
    required by 29 CFR 1910.120(p)(7).
  • 24 hours of initial training.
  • 8 hours of annual refresher training.
  • Employees who enter contaminated areas may need
    to comply with the
  • Safety and health program required by 29 CFR
    1910.120(p)(1).
  • Decontamination program required by 29 CFR
    1910.120(p)(4).

17
Applicability of HAZWOPER to Hazardous Waste
Transportation (cont.)
  • If employees are required to respond to hazardous
    waste emergencies
  • Employees must receive
  • The minimum training required according to their
    emergency response duties required by 29 CFR
    1910.120(q)(6). SARA Sect 303 or
  • Employers must
  • Develop an emergency response program for
    hazardous substance releases in accordance with
    29 CFR 1910.120(q).
  • Develop an emergency response plan in accordance
    with (29 CFR 1910.120(q)(1) and (q)(2).

18
Hazardous Waste Handling Requirements
  • DOT requires that the equipment used for handling
    hazardous waste erials must be of a type that
    does not create a hazard while loading and
    unloading transportation vehicles and rail cars.
  • OSHA has jurisdiction over employee protection
    issues during the use of material handling
    equipment, such as powered industrial trucks,
    overhead and gantry cranes, slings, etc.

19
Personal Protective Equipment Requirements
  • DOT
  • DOT contains regulations for carrier loading and
    unloading, cargo transfer hose connection and
    disconnection, and coupling and uncoupling rail
    cars.
  • However, the DOT regulations do not address
    employee exposure to hazards such as inhalation,
    absorption, ingestion, chemical splash, flying
    particles, and falling objects.
  • OSHA
  • PPE for eyes, face, head, extremities, protective
    clothing, respiratory devices, and protective
    shields and barriers must be provided and used
    wherever it is necessary due to hazards of
    processes or environment, chemical hazards,
    radiological hazards, or mechanical irritants
    encountered that could cause injury or
    impairment.

20
EPAs Hazardous Waste Regulations General
Overview
  • Basic framework of the current hazardous waste
    management program (1976) was developed under
    RCRA
  • Hazardous and Solid Waste Amendments (HSWA) 1984
  • Federal Facilities Compliance Act (1992)
  • Land Disposal Program Flexibility Act (1996)

21
EPA Regulatory Framework Resource Conservation
and Recovery Act (RCRA)
  • Subtitle D establishes a system for managing
    solid wastes in an environmentally sound manner.
  • Subtitle C provides for cradle to grave
    management of hazardous wastes.
  • Subtitle I regulates underground storage tanks

22
Waste Minimization
  • Waste Minimization National Plan
  • Waste Management Hierarchy
  • Comprehensive Procurement Guidelines

23
What is Solid Waste?
  • Can solid waste be a liquid?
  • Municipal Solid Waste (MSW)
  • Non hazardous industrial wastes
  • Hazardous wastes excluded from Subtitle C
    regulations
  • Household hazardous waste
  • CESQGs

24
What is Hazardous Waste?
  • Solid waste which, because of its quantity,
    concentration or characteristics, may pose a
    hazard to human health or the environment

25
Hazardous Waste Identification
  • Is the material a solid waste?
  • Is it a listed hazardous waste?
  • Is it a characteristic hazardous waste?

26
Hazardous Waste Identification Common Violations
  • Generator knowledge or analysis of waste is
    incomplete or inaccurate.
  • The Generator of the waste is responsible for
    knowing what it is!

27
Hazardous Waste Identification Common Violations
  • Wastes are not characterized.
  • Wastes are characterized incorrectly.
  • Unused materials are not characterized

28
Listed Hazardous Waste
  • Wastes from non-specific sources (F)
  • Spent solvents
  • carbon tetrachloride
  • methyl ethyl ketone
  • methylene chloride
  • toluene
  • 1,1,1-trichloroethane

29
Listed Hazardous Waste
  • Unused Commercial Chemical Products
  • Acute Hazard (P)
  • Therapeutic Agents
  • Solvents/Preservatives
  • Sanitizers/Cleaners
  • Laboratory Reagents

30
Listed Hazardous Waste
  • Nonacute hazard (U)
  • Solvents
  • Cytotoxics and other drugs
  • Floor wax
  • Sterilants/disinfectants

31
Characteristic Wastes
  • Ignitability
  • Corrosivity
  • Reactivity
  • Toxicity

32
Those Special Categories
  • Mixture Rule
  • Mixed Waste
  • Medical Waste

33
Those Special Categories
  • Universal Waste

34
Those Special Categories
  • Precious Metals
  • Lead Acid batteries
  • Used oil and oil filters

35
Generator Responsibility
  • Characterize all wastes as soon as they are
    generated.
  • Characterize all unused materials as soon as you
    know they are not going to be used.

36
Generator Responsibilities
  • Determine generator category
  • EPA Identification Number
  • Waste management standards
  • Training
  • Record-keeping and Reporting
  • Pre-transport preparations

37
Generator Responsibilities Generator Status
  • Determine your generator status
  • How much waste do you generate each calendar
    month?
  • LQG gt 1000 kg/mo
  • SQG 100-1000 kg/mo
  • CESQG lt100 kg/mo

38
Generator Responsibilities Generator Status
  • Status can change by month
  • Allowable accumulation quantities and periods vary

39
Generator Responsibilities Waste Accumulation
  • LQG
  • no more than 90 days
  • SQG
  • no more than 180 days

40
Common Violations Waste Accumulation
  • Open, damaged or inappropriate containers
  • Secondary containment
  • Incompatibles
  • Aisle space
  • Signage

41
Common Violations Waste Accumulation
  • Unlabelled containers
  • Hazardous waste
  • Hazardous properties
  • Accumulation start date
  • No conflicting labels

42
Common Violations Satellite Accumulation
  • Waste quantity
  • Where did this come from?
  • Whos minding the store?
  • Routine inspections?

43
Generator Responsibilities Training
  • Training Plan
  • Training program
  • Training Records
  • Annual review

44
Generator Responsibilities Contingency Plan
  • Current, written plan
  • Emergency procedures
  • Emergency Equipment
  • Designated coordinator

45
Generator Responsibilities Preparation for
Transport
  • DOT rules for packaging, labeling, marking and
    placarding
  • Manifests

46
Who must use the Manifest
  • Large or Small Quantity Generators (LQG, SQG)
  • of RCRA hazardous waste who ship their wastes
  • off-site for Treatment Storage or Disposal (TSD)
  • must use the Manifest (EPA form 8700-22/22A)
  • to track these shipments.
  • Anyone who Generates over 100 kg of RCRA
  • waste in any one month (1 kg acute) is an SQG or
  • LQG

47
Manifest Initiation, Movement, and Copy Retention
48
Manifest Initiation, Movement, and Copy Retention
  • The Generator initiates the manifest which
    travels with the transporter to the broker or
    final TSDF. The Generator, transporter, and TSDR
    facility each keep a copy and the TSDR/broker
    mails a return copy to the Generator. Everybody
    keeps their copies for 3years. If a broker bulks
    and re-ships the waste to a final TSDF site, the
    broker creates a new Manifest which must follow
    the same process.

49
How do you complete the Manifest
  • Complete items 1-20 on 8700-22 as required by EPA
  • If needed for additional Wastes
  • Complete items 21-35 on 8700-22A as required by
    EPA

50
Previous manifest to 9/5/2006
51
The new manifest after 9/5/2006
52
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53
RCRA Manifest System
54
DOT Requirements for Transporting Hazardous
Materials
  • Hazardous Materials Regulations (HMR) govern
  • transportation of hazardous materials (49 CFR
    parts 100-185)
  • Definition of hazardous material
  • HMR requires information to communicate
  • hazards during transportation
  • Hazardous Materials Table (HMT) at 49 CFR172.101
    is critical to compliance

55
Information in the HMT (49 CFR 172.101)
  • Proper shipping name
  • ID number
  • Hazard class
  • Packing group
  • Labeling and markings
  • Restrictions and limitations

56
Proper Shipping Names Under DOT
  • Hazardous materials are assigned proper shipping
    names in the HMT
  • The proper shipping name must be used on
    hazardous waste manifests or DOT shipping papers
  • Examples of proper shipping names for hazardous
    wastes are
  • Waste flammable liquids, n.o.s.
  • Waste flammable liquids, corrosive,n.o.s.
    (ethanol, sodium hydroxide)
  • Waste methane

57
Hazard Classes Under DOT
  • Class 1 - explosives
  • Class 2 - gases
  • Class 3 - flammable liquids
  • Class 4 - flammable solids
  • Class 5 - oxidizing substances and organic
    peroxides
  • Class 6 - toxic (poisonous) and infectious
    substances
  • Class 7 - radioactive material
  • Class 8 - corrosives
  • Class 9 - miscellaneous dangerous goods

58
Packing Groups Under DOT
  • Packing groups
  • Group I
  • Group II
  • Group III
  • Criteria for packing groups

59
Placards Under DOT
  • Placard colors, symbols, labels, and numbers
  • Flammables red
  • Explosives orange
  • Nonflammable gases green
  • Corrosives black and white
  • Poisons black and white
  • Oxidizers yellow
  • Exceptions to placarding requirements

60
Label and Marking Requirements for Hazardous
Waste Containers Under DOT
  • Label information required
  • Markings required

61
40 CFR 172.101 Table
62
RCRA Regulations That Apply to Off- Site
Transportation of Hazardous Waste
  • Pre-transport requirements
  • Placarding, labeling, and marking
  • Hazardous waste manifest
  • EPA identification numbers
  • LDR tracking requirements

63
Land Disposal Restrictions
  • Generator determination
  • Generator Paperwork
  • Notification or
  • Certification

64
LDR Tracking Requirements
  • Restricted wastes require the following
    documentation
  • One-time LDR notification (with initial shipment)
    if waste does not meet treatment standards
  • One-time notice and certification if waste meets
    treatment standards
  • Waste analysis information (when available)

65
Record-keeping and Reporting
  • Biennial Reports
  • State Reports
  • Exception Reports
  • Records Retention

66
RCRA Compliance
  • Waste characterization
  • Storage and labeling
  • Contingency plan and training
  • Records and reporting

67
RCRA Compliance Conclusion
  • EPA RCRA compliance does not have to be difficult
  • Ask your EPA Region and/or DOT State for
    assistance
  • Environmental Management System (EMS) can help

68
How to contact me?
  • Eduardo R. González, PE, DEE, MBA, REM, CEA Tel.
    (787) 977 - 5839 Fax. (787) 729-7748 e-mail
    gonzalez.eduardo_at_epamail.epa.gov

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