Annual Training for

Hazardous Waste

GeneratorsPresented at AEF’s April 2018 Regulated Waste Seminar

By: Garrett Mikel

13000 Cantrell Rd.

Little Rock, AR 72223

(501) 975-8100

gmikel@ecci.com

www.ecci.com

• Arkansas Pollution Control & Ecology

Commission Regulation No. 23

“Hazardous Waste Management”

regulates active facilities

• Generators;

• Transporters; &

• Owners & Operators of Treatment, Storage, &

Disposal facilities.

• Section 262.34 references Section 265 (Interim TSDFs)

• All persons who are handling, transporting, or storing hazardous

wastes must be trained within 6 months of their hire date.

– Prior to training, accompanied by trained personnel.

– Annual Refresher Courses

• Instruction in hazardous waste management procedures relevant to

the positions in which they are employed.

– Contingency Plan!

• Records

– Job Title, Description, and Type, Amount, and Frequency of Training

– Retain on current personnel until closure of facility or 3 years from end

of employment.

Annual Training Requirements

• Solid Waste (includes solids, liquids, & gases)

– When it is discarded or abandoned

– When it has no value

– Not necessarily Hazardous

• All Hazardous Waste is Solid Waste

but not all Solid Waste is Hazardous Waste

When is it a “Waste”

• Process Knowledge

• Testing

• Characteristic or Listed?

When is a Solid Waste

Hazardous?

Hazardous Waste

Determination• Characteristic Hazardous Waste

– Ignitable (D001)

– Corrosive (D002)

– Reactive (D003)

– Toxic (D004-D043)

• Based on specified tests or knowledge

– Process knowledge or records of analysis

• CAREFUL!- Must be correct & convincing

• Recommend keeping on-record for 3 years

Hazardous Waste

Determination• Listed Hazardous Waste

– Non-Specific Sources (F)

• Chemicals

– e.g. F002- Spent Tetrachloroethylene (>10% before use)

– Specific Sources (K)

• Industry/Manufacturing Processes

– e.g. K045- Spent carbon from the treatment of

wastewater containing explosives

– Products that become wastes (P or U)

• Off-spec, residues, or contaminated materials

– e.g. U210- Tetrachloroethylene (Sole Active Ingredient)

• Federal Regulations

– 40 CFR 261 Subpart D Tables

• State Regulations

– APC&E Commission Regulation 23

• Incorporates Federal Tables

• Waste Analysis/Characterization Services

• Third Party Waste Management or

Disposal Services

– Generator assumes liability.

Hazardous Waste

Determination Help

• Generating, storing, marketing, burning,

transporting, or disposing of a hazardous

waste

– Complete Form 8700-12: Notification of

RCRA Subtitle C Waste Activity

• Arkansas version available on ADEQ website

• Update form when facility has changes in contact

information, ownership, or waste codes

Notification of Regulated

Hazardous Waste Activity

Generator Status

• Conditionally Exempt Small Quantity

Generators (CESQGs/VSQGs)

– Generate <220 pounds/month

• <2.2 pounds/month Acutely Hazardous (P wastes)

– Accumulate <2,200 pounds

• <2.2 pounds Acutely Hazardous

Generator Status

• Small Quantity Generators (SQGs)

– Generate >220 & <2,200 pounds/month

• <2.2 pounds/month Acutely Hazardous (P wastes)

– Accumulate <13,200 pounds

• <2.2 pounds Acutely Hazardous (P wastes)

• Accumulation time limited to <180 days

– EPA ID Number, Emergency Procedures,

Recordkeeping, & Reporting Required

Generator Status

• Large Quantity Generators (LQGs)

– Generate >2,200 pounds/month

• >2.2 pounds/month Acutely Hazardous (P wastes)

– No Accumulation Weight Limits

• Accumulation time limited to <90 days

– EPA ID Number, Emergency Procedures +

Contingency Plan, Recordkeeping, &

Reporting Required

Accumulation & Storage of

Hazardous Waste• Storage Units

– Containers

– Hazardous Waste Tanks

– Drip Pads

– Containment Buildings

• Satellite & Central Accumulation Areas

Satellite Accumulation Areas

• Container at or near the point of generation– Under the control of the operator

– Containers ≤55 gallons

(≤1 quart Acutely Hazardous)

– Portable & DOT Approved

• Marked “HAZARDOUS WASTE” or other identifying label– All Containers

– No Date (no time limit)

Satellite Accumulation Areas

• Containers in Good Condition– No leaks or deterioration

– Compatible with materials being stored

• Closed Containers– No Spills

• Full containers (55 gallon) must be moved to Central Accumulation Area within 3 days.– Dated (after full or finished using)

– Moved by employee “thoroughly familiar with proper waste handling procedures”

Central Accumulation Areas

• Emptying Containers

– No more than 1 inch of remaining waste

• SQG – 180 days

– Incompatible Wastes

• LQG – 90 days

– Incompatible Wastes

– Ignitable & Reactive Wastes

• Kept away from ignition or reaction sources

• NO SMOKING signs nearby

Central Accumulation Areas

• Weekly Inspections– Leaks, Corrosion, Closed Lids

– Labels, Dates, Containment, Emergencies, Signage, Aisle Space

– Qualified Inspector with Documented Training

Hazardous Waste Labels

Universal Wastes

• Alternative standards for

– Batteries, Pesticides, Mercury-Containing

Equipment, Bulbs &, Consumer Electronics

• Universal Waste Handler Status

– Small Quantity Handlers of Universal Waste

(SQHUW)

• <11,000 pounds on-site

– Large Quantity Handlers of Universal Waste

(LQHUW)

• ≥11,000 pounds on-site

Universal Wastes

• Accumulation time limited to ≤1 year

• EPA ID Number Required for LQHUW

• Employee Training for Handling &

Emergency Procedures

• No Hazardous Waste Manifest Required

• Labeling

– “Universal Waste – Batteries, or Waste

Batteries, or Used Batteries”

• Same for other Universal Waste

Universal Waste Labels

Waste Oil vs. Used Oil

• Waste Oil- Generic Term

– New but may or may not be contaminated by

hazardous substances

– Unusable / No Value

– Not Defined in Hazardous Waste Regulation

• Used Oil- Precise Regulatory Term

– Used and may be contaminated by physical

or chemical impurities

– May be refined and recycled / Valuable

Good Housekeeping

Bad Housekeeping

Safety Procedures

All employees should be aware of the locations of:

• Emergency Plan/Procedures

• Emergency Telephones & Telephone Numbers

• Emergency Evacuation Routes & Exits

• Fire Alarm Pull Stations

• Fire Extinguishers

• Spill Response Kits & Materials

• First Aid Kits

• Chemical Alarms

Contingency Plan

• Each owner or operator must have a

contingency plan to minimize hazards. – Describes actions personnel take in response to fires,

explosions, or any unplanned sudden or non-sudden release of

hazardous wastes.

• Emergency contacts must be listed on the plan.

• Emergency equipment should be listed on the

plan.

• The plan is initially submitted to all local

responders. – Changes to the plan must be resubmitted to each responder.

Transportation & Disposal

• Transport by a permitted Hazardous

Waste transporter

• Hazardous Waste Manifest

• Shipped to a permitted Treatment,

Storage, and Disposal Facility (TSDF)

• DOT Regulations and Restrictions

Return Manifests

• LQG

– Contact Transporter/Disposal Facility

• Within 35 Days

– Report

• Within 45 Days

• SQG

– Report

• Within 60 Days

Annual Hazardous Waste

Report• Due March 1 of every year to ADEQ

• Online using specific ADEQ reporting

forms

• Report describes:

– General facility information

– Amount & type of hazardous waste, universal

waste, & used oil generated during the

previous calendar year by waste stream.

– Shipment information (who shipped it & who

received it)

Summary

• All containers MUST be in good condition – No leaks, bulging,

rusting, damaged, or dented drums.

• All containers MUST be sealed (lids or bungs on) at all times that

waste is not being added or removed.

• If any containers leak - place waste in new or good used empty

drum or overpack.

• DO NOT mix different waste types or use drums that held another

type of material.

Summary

• When emptying any containers, they can have no more than 1 inch

of remaining waste to be considered empty.

• Make sure that all containers are labeled with “Hazardous Waste”

label & that the label is complete – accumulation date, facility name,

waste material, description (waste codes) & other information.

• Satellite Accumulation point is at or near generation point.

• Waste containers CANNOT be stored for more time than allowed by Generator Status.

• Make sure that drums have enough space between them to see the labels & inspect. (3 feet between rows & stacked 2 high max).

Summary

• Inspect containers weekly & DOCUMENT!!!

• Hazardous waste cannot be moved from the satellite area with out being properly labeled.

• Hazardous waste can only be delivered to the hazardous waste storage area by trained employees.

• Hazardous waste must be shipped off-site with a completed Hazardous Waste Manifest.

• Know where the all emergency numbers, fire alarms, fire extinguishers & spill equipment are located.

Your Mission…

• Annual Employee Training Requirements

• Specific Presentations• LQG• SQG

• Contingency Plan!

• Records