Hazardous Waste Annual Training

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Hazardous Waste Annual Training

• The College at Brockport
• Office of Environmental Health and Safety Dave
  Turkow, Dawn Lee and Sarah Klein
• May 27, 2009

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Haz Waste Basics the laws

• EPA 40 CFR, Part 260-279, 1976
• NYSDEC 6 NYCRR, Part 370-374
• Others the may apply TSCA, EPA 760
• Web www.dec.state.ny.us
• OR www.epa.gov
• Questions for NYSDEC
• Bill Yeman 518/402-8633

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NYSDEC Regs

• Part 370 Hazardous Waste General
• Part 371 Identification and Listing
• Part 372 Manifest and generator standards
• Part 373.1 .2 TSDF requirements
• Part 373.3 Standards for operators of hazardous
  waste facilities
• Part 374.2 Used Oil standards
• Part 374.3 Universal waste

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Haz Waste in Colleges ???

• Solid Waste vs. Hazardous Waste
• Must be solid waste to be Haz Waste
• A discarded material or inherently wastelike
• (Regular Trash vs. for Disposal)
• NO LIQUIDS in regular trash
• Containers clean of residual, top off, no free
  liquid, broken glassware sharps hazard,
  pesticides/triple rinse,
• Hazardous Waste Listed in the Regulations or.
• Flammable, Corrosive, Reactive or Toxic
• If it is NOT any of the above it COULD BE regular
  solid waste or testing may be required

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Flammables Ignitable

• Flash Point less than 140 F (not 100 F)
• Flash Point on MSDS temperature where vapors
  are given off which CAN ignite
• Non-waste products less than 100F
• Examples acetone, gasoline, solvents, oil-based
  paint, kerosene, lab chemicals, methylene
  chloride?
• Cannot be stored within 50 of property line
• Pyrophoric or extremely flammable chemicals
  Class 4 NFPA/HMIS

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Corrosive

• pH below 2 or above 12.5
• Sewer ordinance - depends on your local POTW
  (good to know these folks) Pre-treatment ??
• Changing pH is OK IF part of the experiment/lab
  procedure/SOP. Otherwise record it.
• Examples High pH-cleaning products, rust
  removers, low pH-battery acid, sulfuric, nitric,
  chromic, sodium hydroxide, caustics
• Storing incompatibles (Nitric Acid, HF, Bases and
  Acids, Oxidizers, Peroxides)
• Nitric, HF need to be stored separately

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Reactives

• Unstable or explodes when mishandled
• Reacts with water, air, temperature
• Examples old picric acid, ethyl ether, di-nitro
  compounds, perchloric acid
• Metals such as magnesium, sodium
• May not be labeled as reactive when new

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Toxic

• Fails the TCLP (TOXIC CHARACTERISTIC LEACHING
  PROCEDURE) - it can leach from a landfill
• Toxic D-listed waste with a ppm/ppb level
• F-waste spent solvents and mixtures
• K-waste specific industries
• Mixture rule if you mix hazardous with
  non-hazardous, its ALL hazardous
• DEC Website www.dec.state.ny.us/website/regs/inde
  x.html

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Part 371 Indentification Listing of Hazardous
Waste

• http//www.dec.ny.gov/regs/14897.html
• Pretty much the same as EPA, 40 CFR, Part 261
  with exceptions.
• Hazardous Waste Solid waste that is listed in
  one of the 4 lists or exhibits any four
  characteristics 1) ignitable 2) corrosive 3)
  reactive or 4) Toxic TCLP list

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Hazard Codes

• Ignitable (I)
• Corrosive (C)
• Reactive (R)
• Toxicity Characteristic (E)
• Acute (H)
• Toxic (T)
• Included in F, K, U, and P listed indicating
  the primary hazards

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Toxic (continued)

• P list acutely toxic, only 1kg (2.2 lbs.)per
  month
• And.. F20, 21,22, 23, 26
• U list relatively toxic/nasty chemicals
• Unlisted such as ethidium bromide, dispose
  as hazardous???
• B list only in NY, PCBs in transformers
• 50 ppm is the cut off in NYS
• PCB Ballasts, Caulk, etc. covered by TSCA, Part
  261 and EPA Part 761.

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Universal Wastes

• New group with less stringent regulations
• Includes Batteries, Pesticides, Thermostats, and
  Fluorescent bulbs on 1/6/2000.
• Waste Oil w/ no solvent tested, recycled
• Still must label as Universal Waste
• Doesnt count towards waste generation
• 1year for removal
• Broken bulbs are still a question ??
• Point of generation is the building for lamps

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Manifests
http//www.epa.gov/epawaste/hazard/transportation/
manifest/pdf/newform.pdf
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Manifest Requirements

• Must send out copies within 5 business days
• Should receive a copy back within 35 days, if not
  ? contact the TSDF
• If not in 45 days, an exception report must be
  filed _at_ NYSDEC with
• legible copy of the manifest and..
• cover letter w/ efforts to locate

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CATEGORIES OF GENERATOR

• Conditionally exempt small quantity (CESQG)
• lt100 kg. lt1 kg. acute, and lt1000 kg, accumulated
• Small Quantity Generator (SQG) - 180 days
• gt100 kg.but lt1000 kg. per month, lt 1 kg. acute
• Large Quantity Generator (LQG) 90 days
• gt1000 kg. or gt1 kg. acute and any month, or 6,000
  kg. at one time.

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Regulatory Status

• TSDF - tough requirements and financial
  assurance/bonding required
• Therefore
• 90 day storage, begins when it leaves the lab
• LQG storage requirements
• Weekly inspections
• Date on the container, when it leaves lab
• Can change your status yearly or even monthly

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DISPOSAL

• EPA ID NUMBER
• Letter from disposal facility
• Disposal and transport
• Land band restrictions
• Emergency s posted
• Manifested - 8 copies
• Licensed transporter
• Still liable if anything goes wrong
• ONLY net weight not including container

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LARGE Quantity Generator

• Annual Report
• Quarterly taxes
• Yearly taxes
• TRAINING and DOCUMENTATION
• yearly for all those who handle, store, etc.
• Preparedness and Prevention Plan is a Contingency
  Plan in NY
• NY DEC annual audit report for SUNYs

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Contingency Plan (Preparedness Prevention Plan)

• Name, address and phone for emergency coordinator
  can use UP since theyre 24/7
• Personnel responsibilities
• Emergency response s have a vendor on call who
  will respond quickly
• Evacuation plan reference existing plans
• Report requirements in the event of a spill
• Procedures to re-activate the facility
• Required for LQG and SQG

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Major elements of inspections

• Pre-Inspection conference
• Must be accompanied by an employee no free look
  on an official inspection
• RECORDS/PAPERWORK REVIEW
• They know, that you know, that they know
• FACILITY WALK THROUGH
• Will talk to faculty/staff/students with first
  hand knowledge
• If housekeeping is poor (mess), they will look
  harder and ask more questions

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FACILITY WALK THROUGH

• Process generating the waste pure product vs
  waste product codes different for spent solvent
  vs. unused solvent
• Drum/container storage areas
• Signs of spills or leaks
• Incompatible waste stored together
• Aisle space
• Dates, labels, open containers, storage
  containers proper, conditions in general

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Facility walk through (continued)

• Hazardous Waste Storage Area sign must use
  this term, nothing else.
• Labels visible
• No smoking sign
• Emergency spill equipment/supplies
• Internal communications available
• Phone s of emergency personnel, with a procedure
  for reacting, university police
• Dated waste containers, with contents, name of
  generator and any special precautions

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Labs/Hazardous waste inspections - EPA

• Tops on containers tight will it spill if
  tipped?? GC/MS drainage to waste bottle
• Hazardous Waste on the label
• Incompatibles stored together
• Secondary containment tray or other container
• Old bottles of liquid chemicals if it looks
  like it hasnt been used, its inherently
  waste-like
• Open containers in hood w/ residualair violation
• Evidence of a spill/leak
• Attitude of PI/employee/management

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Satellite Accumulation Areas

• Label Hazardous Waste
• At the site of generation Frisbee Rule
• Cannot go to another lab, must go directly to a
  90 day storage area
• Full containers must be removed in 3 days
• No 90 day requirement IN LAB
• Maximum quantity 55 gallons, 1qt. acutely toxic
  (P-listed waste)
• Contents must match written document

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EPA Inspection Tips

• Training not specifically required for
  satellite areas, but must know the basics
• Whoever handles waste should be trained,
  including students
• Old chemicals a potential problem
• Identification of potential hazards could be an
  issue. Knowledge of the chemical better be really
  good if youre claiming its NOT hazardous.

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BE PREPARED

• 1- Clean out labs of old chemicals
• 2- Manage chemicals systematically
• 3- Check all forms of disposal water, sewer,
  air, treatment, recycle/reuse
• Compatible materials stored together
• Emergency response and spill kits
• Manage by walking around, checking

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Other Waste Issues

• Fluorescent lamps universal waste
• Batteries and thermostats universal waste
• Computer monitors, keyboards and CPUs hazardous
  waste. Must be managed as metal
  recovery/recycling
• C-7 notification reqd
• Toxics that are not listed by EPA
• PCB ballasts large quantities should be managed
  as hazardous

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Questions for Dave???????