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Annual RCRA Hazardous Waste Training Program


Mandated annual training for employees who ... Dispose of waste through licensed waste haulers/facilities ... Transport only by licensed Hazardous Waste Hauler ... – PowerPoint PPT presentation

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Title: Annual RCRA Hazardous Waste Training Program

Annual RCRA Hazardous Waste Training Program

CFR 40
  • EPA has implemented
  • Regulations for Identification of wastes
  • Performance standards for generators
  • Hazardous waste facility permit program
  • Mandated annual training for employees who
    handle, process or may regularly be exposed to
    hazardous waste

Training Objectives
  • Understand types of waste generators
  • Define hazardous wastes
  • Describe proper handling and storage of hazardous
  • Select proper waste containers
  • Label and mark waste containers
  • Discuss truck loading requirements
  • Complete paperwork for waste shipment
  • Response to emergencies

Types of Generators
  • Large quantity generates gt1000kg(2205 lbs) in
    any month
  • Small quantity - generates lt1000kg(2205 lbs) in
    any calendar month (approx 5 drums)
  • Never accumulates gt6000kg on site
  • Very small quantity generates lt 100kg per
    month never gt1000kg on site

SQG Must
  • Obtain a USEPA identification number
  • Identify Hazardous wastes
  • Keep records of wastes
  • Inspect waste containers regularly for damage
    document these inspections
  • Dispose of waste through licensed waste
  • Fill-out and retain proper shipping papers

What is a hazardous waste?
  • A solid waste, or combination of solid wastes,
    which because of its quantity, concentration, or
    physical, chemical, or infectious characteristics
  • Cause or significantly contribute to an increase
    in mortality or an increase in serious
    irreversible, or incapacitating reversible
    illness or
  • Pose a substantial present or potential hazard to
    human health or the environment when improperly
    treated, stored, transported, disposed of, or
    otherwise managed.

What is a hazardous waste? Contd
  • Listed Wastes automatically hazardous if it is
    named on RCRA list (gt400 chemicals)
  • Characteristic Waste- waste is
  • Ignitable easily combustible/flammable
  • Corrosive - pH 2.0 or less12.5 or more
  • Reactive unstable or reacts violently with
    water or other materials
  • Toxic if extract has heavy metals, pesticides

What is a Hazardous Waste? contd
  • Acutely Hazardous wastes- these are so hazardous
    (primarily some pesticides or dioxin-containing
    wastes) that generation of 2.2 lbs or having that
    much on-site would be enough to categorize a
    company as a Large quantity generator

RBP waste
  • RBP is a small quantity generator
  • Primary hazardous waste is solvent from tank
    washout. This is collected at a site other than
    the storage site. Suitable container for
    flammable liquid is a steel drum.
  • Satellite waste drum collection in Chem Mix1
    area maximum 55 gals
  • Storage- Flammable Storage Room

Ignitable Wastes
  • Code D001 if
  • A liquid with flash point lt140F exception is an
    aqueous solution with lt24 alcohol
  • A non-liquid capable at 77F and 760mm pressure of
    causing fire due to friction, absorption of water
    or spontaneous reaction and, if ignited, burns

Ignitable Wastes continued
  • It is an oxidizer, such as chlorate,
    permanganate, inorganic peroxide, or a nitrate
    that yields oxygen to stimulate combustion of
    organic material

RBP Waste
  • Corrosive wastes unusable raw materials and/or
    rejected/obsolete products that cannot be
    utilized. Suitable containers are those not
    damaged by corrosive nature of waste.
  • Storage- return area
  • A waste is not a waste until RBP makes the
    determination that we cannot use it.

Corrosive Wastes NR
  • EPA waste code D002
  • Classed as corrosive waste if
  • Aqueous solution wiyh pHlt2 or gt12.5, or
  • Liquid that corrodes plain carbon steel with
    carbon content of 0.20 at rate gt6.35mm/0.25
    year at 55C.

Reactive Waste If
  • ( Code D003 )
  • Reacts violently with water, or
  • Forms potentially explosive mixtures with water,
  • Normally unstable and readily undergoes violent
    change without detonating, or
  • When mixed with water generates toxic gases
    sufficient to be danger to humans

Reactive Waste continued
  • If a cyanide which when exposed to pH between
    2-12.5 can generate toxic gases.
  • example would be the cyanide locked in cabinet
    in Brads area. If we decided we couldnt use it
    or find a user this would be disposed of under
    this hazardous waste code

Toxic Wastes
  • EPA waste codes D004-D043
  • Specific test method used to determine level of
    listed hazardous material. Examples are mercury,
    chromium, lead, pesticides, benzene

Waste Treatment
  • RBP has no permit as a waste treatment facility
  • Elementary neutralization of a waste whose only
    hazard is pH based is allowed as long as
  • it was generated on-site, and
  • is in a suitable container

Hazardous Waste Identification
  • Satellite collection
  • Maximum of 55 gallons
  • Marked as Hazardous Waste and appropriate hazard
    warning flammable, etc.
  • Keep closed at all times when not actively adding
    waste to container. A funnel with a lid is okay
    as long as lid kept closed.

Solvent Waste Collection
Hazardous Waste Identification
  • Once container is full, the date is entered on
    the label as the Accumulation Start Date
  • Container must be removed to the storage area
    within 48 hours
  • RBP, as a SQG, has 180 days to dispose of the
  • The stored waste must be inspected regularly for
    damage. Hazardous Waste Drum Inspection Log
    filled out weekly. Form 13-7.

Waste Transport
  • Transport only by licensed Hazardous Waste Hauler
  • Shipment not accepted without a manifest signed
    by the generator (RBP)
  • Transporter must sign and date manifest
    acknowledging acceptance of the waste and give us
    a copy of the signed document prior to leaving.
  • Manifest must accompany shipment.
  • Receiving TSD must return signed copy of manifest
    to RBP within 30 days acknowledging receipt of
    waste. Not needed if transporter is also the TSD.

Manifest System
  • Uniform Hazardous Waste Manifest info
  • Generator name and address
  • Generator USEPA ID number
  • Manifest Document number
  • Transporter name
  • TSD name and address

Manifest info continued
  • US DOT description of wastes including Hazardous
    Waste ID numbers
  • Number of containers, total quantity
  • Emergency contacts
  • Special handling, PPE, etc.
  • Signed by RBP representative title
  • Signed by Truck Driver
  • Date



EPA Hazardous Waste ID Numbers
  • 40CFR261 Identification and listing of hazardous
  • D001 is code for our ignitable solvent waste

Universal Waste
  • Computer CRTs
  • Fluorescent light bulbs if broken becomes a
    hazardous waste.
  • Thermostats
  • Pesticides
  • Batteries
  • A SQG not required to notify EPA of handling

Universal Wastes
  • Label as Universal Waste Lamp(s)
  • Universal Waste Pesticide(s)
  • Etc.

Waste Minimization
  • RBP signature on Manifest automatically commits
    us to having a waste minimization program
  • Minimize waste by
  • Using out-of-spec product in blend-off program
  • Finding alternate users of off-spec/obsolete
    product or raw materials

Alternate Users must
  • Use 100 of what he takes from us
  • Provide a written agreement signed by a
    representative of that company
  • Use the manifest system to receive it
  • Example is use of our solvent waste for fuel
    value in kilns

Emergency response to a spill
  • Follow our Safety plan procedures
  • Save the people
  • Save the Environment
  • Save the money
  • The first thing to do is recognize the hazard,
    alert supervisor, contain the spill if safe to do
  • Use PA system to alert employees of danger and/or
    need for any evacuation.
  • If spill cant be handled internally, notify
    authorized respondents ( AAA Environmental
    Industries, WA Fire department, etc.) See
    Contingency Plan.

Handling Spills
  • Containment procedures including use of proper
  • Use and recovery of sorbent materials-use minimum
  • Neutralize acid and alkaline spills
  • Minimize dilution of solvent spills
  • Proper handling and containerization of hazardous

Spill Kits at Chem1 Entrance
Spill Kit Pillows- Shipping Dept