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A premier aerospace and defense company
Hazardous WasteBeing Compliant and helping the Environment
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A premier aerospace and defense company
Instructor
Patrick Watson, CHMM
ATK Sporting Group
Transportation/Environmental Compliance
12+ years with Clean Harbors
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y
A premier aerospace and defense company
Duration
Hour and a half
…I COULD take ALL DAY!
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A premier aerospace and defense company
Objective
This basic class will review:
• Waste determination
• Generator/TSDF standards
• Accumulation area requirements
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Accumulation area requirements
• Satellite accumulation area requirements
A premier aerospace and defense company
The Resource Conservation and Recovery Act
Passed in 1976, phased in over four years
Goal: “To protect human health and the environment”
Identifies hazardous waste
Mandates proper handling, storage, transport and
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a dates p ope a d g, sto age, t a spo t a ddisposal of hazardous waste
States have the right to administer
• States may be more stringent or broader in scope
• California, Minnesota, Massachusetts, Etc!!!!
A premier aerospace and defense company
Section 1
Hazardous Waste Identification
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Hazardous Waste Determination
Is it a waste?
Is it exempt?
Is it listed?
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Is it characteristic?
Is it regulated by State?
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Discarded Materials
First, these regulations only apply to materials that are being discarded or abandoned.
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Waste Bull’s-Eye
Discarded Materials
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Solid Wastes
Hazardous Wastes
Products used for their intended purpose are not being discarded.
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A premier aerospace and defense company
Solid Waste and Hazardous Waste
For us to understand what hazardous waste is, we must understand the term solid waste.
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Solid Waste
Statutory Definition:
“Any garbage, refuse, sludge from a wastewater treatment plant, water supply treatment plant, or air pollution control facility, and other discarded
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pollution control facility, and other discarded material, including solid, liquid, semisolid, or contained gaseous material, resulting from industrial, commercial, mining, and agricultural operations and from community activities.”
AKA, the stuff you are discarding.
A premier aerospace and defense company
Solid Waste
Regulatory Definition:
• Materials that are abandoned;
• Materials that are recycled;
• Materials that are inherently waste-like; and
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Materials that are inherently waste like; and
• Waste military munitions. Solids
Liquids
Semisolids
Gases
Solid waste does not have to be “solid”
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Solid Wastes
Discarded Materials
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Solid Wastes
Hazardous Wastes
Here is a drum of an out dated chemical. It can not be used, thus you want to get rid of it.
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Excluded From Being Solid Wastes
Domestic sewage
Industrial wastewater discharge regulated under the Clean Water Act
S t l
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Scrap metal
Nuclear material regulated under the AEA of 1954
Pulping liquors that are reclaimed
Spent sulfuric acid used to produce virgin sulfuric acid
These are discarded, but are excluded from being solid waste
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Excluded From Being Solid Wastes
Discarded Materials
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Solid Wastes
Hazardous Wastes
Lead scrap is discarded, but is not classified as solid waste since it gets recycled into new lead.
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A premier aerospace and defense company
Hazardous Waste
Statutory Definition:
“A solid waste, or combination of solid waste, which because of its quantity, concentration, or physical, chemical, or infectious characteristics may (a) cause, or significantly contribute to, an increase in mortality or an increase in serious irreversible, or
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or an increase in serious irreversible, or incapacitating reversible, illness; or (b) pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, or disposed of, or otherwise managed.”
Bla, bla, blaWake me when it’s over.
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Hazardous Waste
In other words, a hazardous waste is a solid waste which is hazardous (to you or the environment).
There are four ways a material can be a hazardous waste.
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1.Ignitable
2.Corrosive
3.Reactive
4.ToxicWe will look at
each one in just a minute.
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Solid Wastes
Discarded Materials
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Solid Wastes
Hazardous Wastes
Here is a drum of an out dated chemical. It can not be used, thus you want to get rid of it. This chemical is an ignitable liquid.
To be classified as hazardous waste, the solid waste must be:
Ignitable,
Corrosive,
Reactive, or
Toxic
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Excluded From Being Hazardous Wastes
Household waste
Mining overburden returned to the mine site
Fly ash waste, bottom ash waste, etc.
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Industrial process wastes which fail the test for TCLP exclusively for trivalent chromium
Cement kiln dust
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Excluded From Being Hazardous Wastes
Discarded Materials
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Solid Wastes
Hazardous Wastes
Household waste collected by the city for safe disposal. This drum contains pool chemicals which are corrosive, but they are specifically excluded.
As you see, hazardous wastes are a subset of solid wastes.
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Hazardous Waste Determination
The generator must…
1. Determine if the waste is excluded.
2. Determine if the waste is listed.
3. Determine if the waste is characteristic.
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4. Finally, determine if the waste is regulated by State.
This can be done by testing or applying knowledge.
(M)SDS
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A premier aerospace and defense company
Hazardous Waste Identification
How do you sail around the world?
How do you fly?
How do you go to the moon?
How do you classify hazardous waste?
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o do you c ass y a a dous aste
• This was something completely new.
• EPA was challenged to define hazardous waste, then regulate it.
We’ve already covered exclusions….
A premier aerospace and defense company
Hazardous Waste Identification
EPA decided to go to big industry (sources) to see what wastes they produced.
• Organic chemical manufacturing
• Inorganic chemical manufacturing
• Explosives manufacturing
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• Pesticide manufacturing
• Petroleum refining
Of all the wastes they produced, EPA decided to regulate the ones that were inherently hazardous.
A premier aerospace and defense company
Hazardous Waste Identification
EPA then decided to examine the major processes (non-specific sources) in the US.
They examined the most common chemicals used in many processes across the US.
• Degreasing operations
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• Degreasing operations
• Solvents
• Electroplating operations
Again, EPA regulated the hazardous ones.
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A premier aerospace and defense company
Hazardous Waste Identification
EPA then realized that many chemicals were disposed of because they were kept past there shelf life.
Many unused chemicals were being disposed of because they were outdated.
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•Acetone
•Benzene
•Chloroform
EPA decided to regulate these virgin (unused) chemicals, off-spec versions, and spills of them.
A premier aerospace and defense company
Hazardous Waste Identification
There are over 5,000,000 known chemicals.
It’s common for a virgin hazardous chemical to not receive a P or U code.
It’s common for a hazardous process waste stream not to receive a K or F code
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to receive a K or F code.
EPA needed to make a safety net.
A premier aerospace and defense company
Hazardous Waste Identification
EPA then made waste classifications for materials that exhibited a hazardous property.
• Ignitable
• Corrosive
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• Reactive
• Toxic
These classifications acted as a safety net so hazardous chemicals would not go to non-haz landfill (and into groundwater).
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Characteristic Hazardous Wastes
D001 Ignitable
D002 Corrosive
D003 Reactive
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D004- Toxic (Specific)D043
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Ignitable – D001
Ignitable, compressed gases
Liquid with flashpoint < 1400F
Solids, other than gases that, may cause fire through friction, absorption of moisture, or
t h i l h
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spontaneous chemical changes
Oxidizers and organic peroxides
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Corrosive – D002
Aqueous solutions with a pH of less than or equal to 2 or greater than or equal to 12.5
Liquids which corrode steel faster than .250 inches per year
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1 2 3 4 5 6 |7| 8 9 10 11 12 13 14
Acids Neutral Bases
Must contain water!
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Reactive – D003
Unstable and readily undergo violent change
Can react violently with water
Can form potentially explosive mixtures with water
Readily capable of detonation or explosive decomposition
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Most 5.2s do not fit the D003 definition.
Generally, only 1.1, 1.2 and 1.3 – not 1.4S
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Reactive – D003
• Generates toxic gases, vapors or fumes when mixed with water• Cyanide or sulfide bearing waste that can produce toxic gases
when mixed with pH conditions between 2 and 12.5(Sodium cyanide, potassium cyanide, gold cyanide, lead sulfide, sodium sulfide, silver sulfide)
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• Capable of explosion if heated under confinement
• DOT Forbidden Explosives
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Toxic D004 – D043
Materials that fail T.C.L.P.
Testing shows if hazardous constituent can be leached out of a sample.
If we put this into a non-haz landfill, could it leach
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harmful substances into our drinking water?
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Toxic D004 – D043
These are specific metals, pesticides, organic compounds and herbicides.
Only hazardous waste if found at or above the regulatory limit.
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regulatory limit.
Example: Lead is only a hazardous waste if tests find the level to be 5.0 mg/liter or more.
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State Wastes
States can administer their own RCRA Programs, and can be more stringent.
• Minnesota has its own toxicity waste code
• Texas has build your own waste code
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• Texas has build your own waste code.
• California makes it up as they go along??
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Identifying Hazardous Waste
F codes or K codes
D codes State codes
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P codes or U codes
D codes State codes
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A premier aerospace and defense company
Identifying Hazardous Waste
F codes or K codes
D codes State codes
Listed Wastes
Characteristic Wastes
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P codes or U codes
D codes State codes
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Manifesting of Hazardous Waste
If a waste receives any listed or characteristic code, the material is deemed a hazardous waste.
RCRA goes on to say hazardous waste must be transported on a hazardous waste manifest.
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Manifesting of waste is a safetyspecific function (hint hint)
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Identify the waste code(s)
Unused drum of Ethyl Acetate
It is past its expiration date, we can’t use it anymore.
We’ve never opened the drum.
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Unused = virgin = U112
DOT hazard class = 3 = D001
This material is EPA/RCRA hazardous waste with codes U112 and D001.
UN1173, Waste Ethyl Acetate, 3, PGII
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Copper Electroplating Solution containing copper, lead, potassium cyanide and potassium hydroxide.
Spent Electroplating Waste = F006
Identify the waste code(s)
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Spent cyanide = D003 (no P-code, spent!)
Lead = D008
Copper = No Codes
Potassium Hydroxide (pH > 12.5) = D002
RQ, UN1935, WASTE CYANIDE SOLUTIONS, N.O.S., (POTASSIUM CYANIDE, LEAD), 6.1, PG II (D002, D003, D008, F006)
A premier aerospace and defense company
Identify the waste code(s)
Unused bottle of lead nitrate
Unused lead nitrate = no U or P codes
DOT hazard class = 5 1 = D001
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DOT hazard class = 5.1 = D001
Material contains lead = D008
This material is hazardous waste with the codes D001 and D008.
UN1469, Waste Lead Nitrate, 5.1(6.1), PGII
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Questions
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Section 2
Generation & Accumulation
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A premier aerospace and defense company
Hazardous Waste Generation
Generator Status
• Determined by weight and type of waste generated
Generator Max. Weight (Codes)
Max. Acute (P-List)
Accumulation Time
Quantity Limit
Large Quantity
> 1000 kg/month
> 1 kg/month
90 days NONE
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Quantity (LQG)
kg/month kg/month
Small Quantity (SQG)
< 1000 kg/month
< 1 kg/month
180 days < 3000 kg
CESQG < 100 kg/month
< 1 kg/month
NONE < 1000 kg
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Hazardous Waste Generation
Registration
• Federal (US Gov):
– CESQG generally doesn’t have to do “anything”
– SQG and LQG must register with EPA and receive an EPA ID#
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– TSDF must be permitted.
• State:
– Good luck
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A premier aerospace and defense company
Hazardous Waste Generation
Generator Requirements
• Accumulation time limits
• Start date and “Hazardous Waste” must appear on container
• Ignitable wastes and reactive wastes must be stored at l t 50 f t f t li
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least 50 feet from property line
• Must always have one person on call or on premises in case of emergency
• Must have emergency information next to phone
• Biennial Reporting Required (Every 2 years)
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Hazardous Waste GenerationGenerator Requirements
• Must train all employees with proper waste handling techniques and contingency plan implementation
• Must review training annually
• Facility must have
Hazardous Waste Generation
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– Internal communication or alarm system
– Telephone or two way radio
– Fire control equipment
– Spill control equipment
– Decontamination equipment
– Water at adequate volume and pressure
Must be tested and maintained!
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Hazardous Waste GenerationGenerator Requirements
• Must have aisle space between containers
• Must have prior arrangements with
– Police
Fire department
Hazardous Waste Generation
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– Fire department
– Local response teams
– Emergency response contractors
– Equipment suppliers
– Hospitals
• Must have contingency plan & Emergency Coordinator!
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• Treatment, Storage or Disposal Facility (TSDF)
• 1 year onsite storage of waste
• Requirements:
• Obtain/maintain appropriate permits
• Comply with permit requirements
Hazardous Waste Generation
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Comply with permit requirements
• Ignitable, reactive wastes must be > 50ft from property line (No Smoking Signs)
• Comply with Generator requirements
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Hazardous Waste Accumulation Area
TSDF
• Ship < 1 year
Large Quantity Generators
• Ship every 90 days
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Small Quantity Generators
• Ship every 180 days (or 270)
CESQG
No requirements for shipments
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Improper/Inadequate Storage
• Main cause of releases
Store to protect human health/environment
Hazardous Waste Generation
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A premier aerospace and defense company
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A premier aerospace and defense company
Hazardous Waste Accumulation Area
Hazardous Waste Accumulation Area (Primary)
• Secured • Clearly posted “HAZARDOUS WASTE”• Clearly marked boundaries
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• Impervious surface• Secondary Containment?• Aisle space (what can you see?)• Documented inspections
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Secondary Containment
Not a Federal requirement for Gen.
TSDF Requirements
• Impervious Surface
Hazardous Waste Accumulation Area
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Impervious Surface
• Free of cracks & gaps
• Sloped
– Not required if palletized
• Storm water kept out
• Material removed in a timely manner
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A premier aerospace and defense company
Hazardous Waste Accumulation
Good idea or bad idea?
ABC ChemicalABC Chemical
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Haz Waste Accumulation Point
Lake, Pond, Stream, Ditch
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Hazardous Waste Accumulation
Haz Waste Accum
Good idea or bad idea?How could it be better?
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School
ABC ChemicalABC Chemical
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Hazardous Waste Accumulation
Haz Waste Accum
X
Fence w/signage
X
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“Bermed” Blacktop
X
X
X
XX
X
X
Much Better!
ABC ChemicalABC Chemical
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A premier aerospace and defense company
Hazardous Waste Accumulation
Container Selection
• Must be in good condition• Free of cracks or punctures
• Little or no rust
• No leaks
HAZARDOUSWASTE
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• Compatible with waste
• Capable of being tightly closed
• Must meet UN specifications if being shipped off site
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A premier aerospace and defense company
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A premier aerospace and defense company
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A premier aerospace and defense company
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A premier aerospace and defense company
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A premier aerospace and defense company
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A premier aerospace and defense company
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A premier aerospace and defense company
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A premier aerospace and defense company
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A premier aerospace and defense company
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A premier aerospace and defense company
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A premier aerospace and defense company
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A premier aerospace and defense company
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A premier aerospace and defense company
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Dupont “Boneyard”Dupont “Boneyard”
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Container Selection
If container condition is compromised, we must transfer materials or use salvage drum.
Salvage Salvage DrumDrum
OR
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EPA and DOT require this.
DrumDrum
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Container Markings
While accumulating at the generator’s site, a container of hazardous waste must have, at a minimum:
• The words “Hazardous Waste”, and
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• Accumulation start date
This information is used to warn people and show compliance with the 90day/180day/1 year rule.
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Container Markings
Like these…
HAZARDOUSWASTE
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WASTEACCUMULATIONSTART DATE _______________________________CONTENTS ________________________________
HANDLE WITH CARE!CONTAINS HAZARDOUS OR TOXIC WASTES
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A premier aerospace and defense company
Container Markings
Some generators apply this marking to the container rather than the minimum. This marking is required when shipping off-
RQ, UN1268 Waste Petroleum Distillates, n.o.s. (Naptha), COMB, PG III
COMB
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q pp gsite.
000917645FLE 2/1/2010
Federal Cartridge
900 Ehlen Drive
Anoka MN 55303
MND006156590 Ignitable, Toxic
D001, D005
CH309725 Mineral Spirits
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Hazardous Waste Marking Requirements
• Hazardous Waste Warning Statement
• Generator's Name and Address
• Generator's EPA Identification Number
• Manifest Document Number
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• Accumulation Start Date
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Hazardous Waste Accumulation
Isn’t all this a pain?
Isn’t there an easier way to accumulate waste?
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Satellite Accumulation Area (SAA)
… a collection of waste or waste containers at or near the point of generation and under the
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gcontrol of the generator
“Under the control of the generator” does not mean you have to be standing next to it the entire time.
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Managing a Satellite Accumulation Area
UNDER THE CONTROL OF THE OPERATOR:
• Direct visual control…or,
• Documented weekly inspections
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• Documented weekly inspections
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Satellite Accumulation Area (SAA)
Up to 55 gallons for non-acutely hazardous waste
Up to 1 quart for acutely hazardous waste
Must be from a single process
Must be closed unless in use
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Containers should be in good condition
Containers should be stored in a safe area
No accumulation time limits
When filled, container must be moved to storage area within 72 hours
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Satellite Accumulation Area
Waste mineral spirits are poured into an
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paccumulation drum in the Satellite!
When full, we have 3 days to move the drum to the accumulation area.
The 1 year time limit begins when the container limit is reached.
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Satellite Accumulation Marking Requirements
• The words “Hazardous Waste” , or
• The name or description of the waste (i.e. “Waste Acetone”)
• Containers must be marked
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HAZARDOUSWASTE
ACCUMULATIONSTART DATE _______________________________CONTENTS ________________________________
HANDLE WITH CARE!CONTAINS HAZARDOUS OR TOXIC WASTES
Mineral spirits
Mineral spirits 100 D001, D005
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Questions
Questions?
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