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DEP Hazardous Waste Program. Why a need for regulations. Following WWII, manufacturing was booming and large volumes of toxic waste were generated. The waste was disposed on ground or burned without controls Problems started developing Water polluted Air pollution Dying species - PowerPoint PPT Presentation
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DEP Hazardous Waste Program
Why a need for regulations
Following WWII, manufacturing was booming and large volumes of toxic waste were generated. The waste was
disposed on ground or burned without controls
• Problems started developing– Water polluted– Air pollution – Dying species– Health problems
• Several sites became legendary– They help cause the creation of environmental protection laws
Some sites became legendary
• Love Canal
• Cuyahoga River
• Valley of the drums
• Times Beach
Love Canal, Niagara NY
15 acres along Niagara River1890, constructed 3000ft by 60ft canal – went bankrupt1920, purchased by Hooker Chemical1920 – 1953, used as a landfill by Hooker Chemical and the city.1953, sold to the city’s board of education ($1.00)Deed stated not to dig within the area of the canal1954, Board of Ed built schools and housing (1000)
Disregarded warning on deed Chemicals seeped into basements and storm drainsDrums popping up in ball fields and yardsResidents started complaining
1978, years of residents complaints forced evacuation of several city blocks2010, a few city blocks still restricted
Cuyahoga River, Cleveland OH
1936 – 1969, used as an industrial sewerNumerous fires from waste chemicals floating on the riverReferred to as the “dead river”. No signs of life in the river
1952, large fire damaging boats and buildings1969, last large fire
Earth movement and Clean Water Act of 1970 put an end to industrial dumping
Valley of the Drums, Brooks KY
13 acre site, gravel pits owned by A. L. Taylor1967 – 1977, took in over 38,000 drums of waste from area paint and coating manufacturers11,000 drums buried and/or burned27,000 drums stored on the soil1980, EPA begins cleanup
Times Beach, MI
Small town of 2000 with 21 miles of un-paved roads1971 – 1972, Sixty two horse die at area stables.
Russell Bliss was hired to sprayed waste oil for dust control 1972 – 1976, Times Beach hires Russell Bliss
Spray waste oil on roads for dust control1977, EPA begins investigation into horse deaths
Oil came from NE Pharmaceutical and Chemical CorpMade Agent Orange (2,4,5T and 2,4D)Contains dioxinRussell Bliss picked up waste oil
1983, EPA purchases the town and evacuates residents1996 – 1997, incinerate 26,000 tons of dioxin contaminated soil
from Times Beach and local stablesCurrent – Town park (still polluted)
Hazardous Waste Laws
• Title 40 of the Code of Federal Regulations, Parts 260 – 280
Cradle to Grave “you generate a waste, you own it forever”
Enforcement
• Civil – – $25,000 per day per violation
• Criminal – – $50,000 per day per violation– Up to five years in prison
Civil Cases
• Home Depot (9 stores)– $425,000.00 & corporation wide compliance program in CT
• Light Sources– $857,000.00 & clean up mercury release
• Kaman Aerospace– $420,000.00
Criminal• Phoenix Products
– $250,000.00– Probation
• Mike Fretaus and U Haul– $60,000.00– 1 year prison
• Sound Mfg– $100,000.00 and $1,000,000.00 cash bond (clean up)– 3 years prison (suspended on appeal)– 1 year home confinement– Clean up completed in January 2010
Questions
Hazardous Waste Management Regulations
As a generator of HW, you must:
• Determine if each solid waste is HW• Properly manage & store the waste• Inspect waste & emergency response equipment• Plan for Emergency responses• Train employees• Preparing for off-site shipment• Keep records
Determination if Waste is HazardousCan use knowledge of the chemicals and process that
generates the waste, analytical testing, or both
• 1st – is the waste a solid waste– i.e. is it discarded
• 2nd – is the solid waste excluded– If no,
• 3rd – is the solid waste a hazardous waste
What’s a Solid Waste• Discarded material –
Spent material Sludge By-product Commercial chemical product Scrap metal
That’s discarded –
Burned/incinerated Recycled/reclaimed Accumulated speculatively Used in a manner constituting disposal*
*placed on land or water
Solid Waste Example
discarded
disposed
burned
reused
What’s a Hazardous WasteA hazardous waste is a solid waste that is
• listed as a hazardous wastes
and/or
• Exhibits a characteristic of a hazardous waste
• Two sub-categoriesUsed oil
Universal waste
Exclusions
• Waste fuel reused as a fuel– gasoline sent off-site for fuel blending
• Effective substitute for a commercial chemical product, provided the product is not used in a manner constituting disposal or burned.
– Spent plastic bead blast media (removing paint from air craft)– Used in water resistant concrete block (Sealtech block)
– Applied above ground – not solid waste– Applied on the ground – is solid waste
– Fly ash used to make zinc powder (electric plant emission control) – Used for galvanizing – not solid waste (US Zinc)– Used in plant food – is solid waste (Bay Zinc)
Waste Codes
• All hazardous wastes are identified by a “waste code”• (except for used oil and universal waste)
• The listed waste codes
• F, K, U, P• (Example – F001 spent halogenated solvent)
• The characteristic waste codes• D waste codes
• (Example – D008 lead)
Reasons for Waste Codes
National statistical informationObserve trends in waste generation
Pollution prevention programsEliminate/reduce large volume waste types
Hazard recognitionWaste codes represent specific hazards
Listed Hazardous Waste• Three Lists (developed in 1976)
– Non-specific source list• Waste from a process that any business can do
– Specific source list• Waste from specifically listed types of businesses
– Commercial chemical product list• Waste that is a specifically listed type of chemical product
Facts about Listed HW
Reasons for Listing
Ignitable (I)Corrosive (C)Reactive (R)Acutely Hazardous (H)Toxic (T)
Mixture Rule
– mixing a listed waste with any other solid waste makes the entire mixture a listed waste!
– not dependent on amount (one drop, one gallon, etc).
– not dependent on the source (intentional mixing, accidental mixing).
– Can cause an inexpensive waste to become more expensive when shipped off-site
Non-specific source“F” Waste Codes
Waste from generic sources:F001 – F039
• Solvents (F001 – F005)
• Metal finishing (F006 – F019)
• Pesticides/wood preservative [dioxin] (F020 - F035)
F001 (T) Spent halogenated solvent used in degreasing
• Carb cleaner• Brake cleaner• Contact cleaner
• tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1 trichloroethane, carbon tetrachloride, chlorinated fluorocarbons
• still bottoms from recovery of spent solvents
F002 (T) the following spent halogenated solvents
• Paint stripper• Tire cleaner• Lab analysis
• tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1 trichloroethane, carbon tetrachloride, chlorinated fluorocarbons
• still bottoms from recovery of spent solvents
Halogens
Chemical with the word chlor or fluor in its name
Perchloroethylene (1.6)Trichloroethylene (1.46)
methylene chloride (1.33)
“HEAVIER THAN WATER”IMPROPER TREATMENT = DIOXINS
F003 (I) The following spent non-halogenated solvents
• Paint stripper• Carb cleaner• Brake cleaner• Electric contact cleaner• Lab analysis
• xylene, acetone, ethyl acetate, ethyl benzene, ethyl ether, methyl isobutyl ketone, butyl alcohol, cyclohexanone, methanol
• still bottoms from recovery of spent solvents
F005 (I)(T) The following spent non-halogenated solvents
• Carb cleaner• Brake cleaner• Paint stripper• Gasket remover• Electric contact cleaner• Lab analysis
• toluene, methyl ethyl ketone, carbon disulfide, isobutanol, pyridine, benzene, 2-ethoxyethanol, 2-nitropropane
• still bottoms from recovery of spent solvents
Specific Source“K” Waste Codes
Waste from specifically identified industrial sources:
K001 – K160• Refineries (K048, K170)
• Pharmaceutical (K084, K101)• Foundry (K061, K069)• Explosives (K044, K45)
ExampleIndustry and EPA hazardous waste
No.
Hazardous waste Hazard code
Wood PreservationK001
Bottom sediment sludge from treatment of wastewater from wood preserving process that uses creosote and/or pentachlorophenol
(T)
Inorganic PigmentsK002
Wastewater treatment sludge from the production of chrome yellow and orange pigments
(T)
Organic ChemicalsK013
Bottom stream from the acetonitrile column in the production of acrylonitrile
(T, R)
ExplosivesK044
Wastewater treatment sludge from the manufacturing and processing of explosives
(R)
Commercial Chemical Product“U” & “P” Waste Codes
SolventsPesticides
PharmaceuticalsChemical ingredients
Commercial Chemical Product Waste
• Waste chemical product that is unused• pure or technical grade of chemical• sole active ingredient• no longer needed or wanted
off-specification old/outdated
Commercial Chemical Product Waste
• Spilled virgin chemical products
Commercial Chemical Product “P” Listed Waste“acutely hazardous”
P001 - P205(H)- Methyl parathion P071
- Nicotine P075– Epinephrine P042
– Methyl isocyanate P064
– Empty containers of “P” listed materials not triple rinsed
– Rinsate from rinsing empty containers
Commercial Chemical Product“U” Listed Waste
U001 – U411(T)– Acetone U002 (I)– Methylene chloride U080– 2,4-D U240 – Isopropanol U140 (I)– Methyl ethyl ketone U159 (I)– DDT U061– Warfarin U248– Acetyl chloride U006 (C, R)
Characteristic Hazardous Waste
Four types“D” waste codes
–Ignitable (D001)–Corrosive (D002) –Reactive (D003)–Toxicity Characteristic (D004-D043)
Some Facts about Characteristic Waste
• Some characteristics are based on physical properties
• flash point• pH (acid or alkali)• compressed or pressurized gases• oxidizer
Some Facts about Characteristic Waste
• Some characteristics are based on concentration limits
• milligrams per liter (mg/L)
• test method “Toxicity Characteristic Leaching Procedure”
• limits range between 0.008 to 400 mg/L
note: one percent (1%) equals 10,000 ppm
Some Facts about Characteristic Waste• Everything discarded, must determine if it exhibits a
characteristic of a hazardous waste
– Paper (masking materials, sandpaper, coveralls)– Tires– Chemicals (used & un-used)– Light bulbs/tubes – Electronic devices (computers, cell phones, TV)– Scrap metal– Paint (liquid or solid)– Contaminated debris (paint brushes, speedi dry, dust)
Ignitable Characteristic“D001”
• Liquid with a flash point less than 140 Deg. F• Oxidizers• Ignitable compressed gases• Not a liquid – fire through friction, moisture,
spontaneous chemical change, & burns vigorously and persistently
Ignitable Examples• Liquid – flash point less than 140
– Mineral spirits– Gasoline– Contact cement– Aerosol paint
• Oxidizers– Nitric acid– Fiberglass resin hardener (MEKP)
• Ignitable compressed gas– Acetylene– Propane
• Not a liquid– Aluminum fines– Magnesium
Corrosive Characteristic“D002”
• Aqueous liquid, pH less than 2 or greater than 12.5.
• A liquid that corrodes steel at greater than 0.025 inches per year at 130 degrees F.
Corrosive Examples
• pH less than 2– Nitric acid (lab)– Sulfuric acid (battery)– Muriatic acid (concrete)– Hydrofluoric (aluminum)
• pH greater than 12.5– Potassium hydroxide (oven)– Sodium hydroxide (drain)– Ammonium hydroxide (cleaner)– Sodium hypochlorite (bleach)
Reactive Characteristic“D003”
• Normally unstable
• Reacts violently with water or forms toxic fumes or vapors
• Capable of detonation or explosion when heated under confinement or initiating force
Reactive Examples• Explosives
– Fire works– Ammunition– Air bags
• Compressed cylinders– Aerosol cans– Propane cylinders
• Metal fines– Aluminum
• Lithium– Batteries with a charge
Toxic Characteristic“D004 – D043”
• 39 elements and compounds
• cause damage to tissue, impair CNS, cause severe illness or death when ingested, inhaled, or absorbed.
• based on concentration limits (mg/L).
• testing using Toxicity Characteristic Leaching Procedure (TCLP).
Toxic CharacteristicWaste Code Contaminant Limit mg/LD004 arsenic 5.0 D005 barium 100.0D006 cadmium 1.0D007 chromium 5.0D008 lead 5.0D009 mercury 0.2D010 selenium 1.0D011 silver 5.0D012 endrin 0.02D013 lindan 0.4D014 methoxychlor 10.0D015 toxaphene 0.5D016 2,4-D 10.0
Toxic CharacteristicWaste code Contaminant Limit mg/LD017 2,4,5-TP 1.0D018 benzene 0.5D019 carbon tetrachloride 0.5D020 chlordane 0.03D021 chlorobenzene 100.0D022 chloroform 6.0D023 o-cresol 200.0D024 m-cresol 200.0D025 p-cresol 200.0D026 cresol 200.0D027 1,4-dichlorobenzene 7.5
Toxic CharacteristicWaste code Contaminant Limit mg/LD028 1,2-dichloroethane 0.5 mg/LD029 1,1-dichloroethylene 0.7 mg/LD030 2,4-dinitrotoluene 0.13 mg/LD031 heptachlor 0.008 mg/LD032 hexachlorobenzene 0.13 mg/LD033 hexachlorobutadiene 0.5 mg/LD034 hexachloroethane 3 mg/LD035 methyl ethyl ketone 200 mg/LD036 nitrobenzene 2 mg/LD037 pentachlorophenol 100 mg/LD038 pyridine 5 mg/LD039 tetrachloroethylene 0.7 mg/LD040 trichloroethylene 0.7D041 2,4,5 trichlorophenol 400.0D042 2,4,6 trichlorophenol 2.0D043 vinyl chloride 0.2
Questions
Managing Waste in Containers• Two types
– Satellite containers– Storage containers
Satellite Containers
– At or near the point of generation– Under control of the operator (generator of waste)
– Can’t exceed 55-gallons per waste type– Labeled “hazardous waste”
– Labeled “description of waste”– Keep closed
– Good condition
Storage Containers• Not a satellite container
• Keep closed• Labeled “hazardous waste”
• Labeled “description of waste”• Labeled “date of accumulation”• Kept in engineered storage area
• Ship off-site in 180-days
Engineered Storage Area• Secondary containment
– 10% of all containers or 100% of largest
• Impervious base– Poly spill pallets– Epoxy coated concrete– Sheet metal
• Warning signs– No smoking signs (flammable or reactive)
• Aisle space– 30 inches between rows of drums
• Secured & 50 feet from property line– Flammable or reactive
• Separate incompatibles– Acid from alkali– Flammable from corrosives
Satellite Violations
open open
Labeled HWOpen, not labeled
Storage Violations
date Containment, labeled (HW, desc, date)
Open, containment, labeled (HW, desc, date) Containment, labeled (HW, desc, date)
Inspections
•Schedule•Describes what to inspect
•Container condition (leaks, damage, bulging)•Container labeling (words HW, description, date)•Containment system (damage, signs of leaks/spills)•Emergency equipment
•Log•Record observations•Name of inspector•Date of inspection•Time of inspection•Corrective action
Inspections
• Frequency– Container areas – weekly– Safety/emergency equipment - monthly
Emergency Response Plan
Emergency Response Plan• Identify key employees
• Emergency coordinator• Alternate coordinator
• Plan for site specific emergencies• Spills, fires, flooding
• at minimum – must contain releases/spills • Hazards of your chemicals• Volume of chemicals (container/tank size)• Site characteristics
• Floor drains• Chemicals stored outdoors
• Soil or asphalt• Possible incompatible materials• Sources of ignition
Post Emergency Information
• Name and phone # of emergency coordinators• Location of spill response equipment• Location of fire extinguishers and/or pull boxes• Phone number for off-site responders (FD, spill
contractors, DEP)• Evacuation routes
Responding• You are required to contain releases
– Train key employees – keep adequate response equipment on-site
• absorbents (clay litter, pads, pigs, saw dust, sand, rags, etc)• shovels• booms (contain spills to water)• fire extinguishers• protective gloves• containers for waste collection
Reporting
– Notify DEP (860-424-3338)• required for all spills
– Notify national response center (800-424-8802)• impacts water body• impacts adjacent properties
Employee Training All employees that have hazardous waste duties
Site coordinatorsworkers putting waste in containersworker conducting inspectsresponding to emergenciesdetermining if waste is HWprepare/sign manifests
Annual training/refresherspecific to worker’s duties involving HW document training
Off-site Shipment• Label container with HW Marker
• Use DOT approved containers
• Label with DOT labels– Corrosive– Flammable
• Use transporter that has EPA Id. No.
• Send to TSDF that has EPA Id. No.
Off-site Shipment• Prepare hazardous waste manifest
– Site address– Volume of waste– Description of waste (and waste codes)– Transporter name and EPA Id. No.– Receiving facilities (TSDF) name and EPA Id. No.– Generator signs and dates
• Keep copy for your file
– Transporter signs and dates – Send a copy to the generator state’s DEP– Send a copy to the receiving facility’s state DEP– Receiving facility sends you a signed dated copy after receiving the waste
• Keep copy for your file
Off-site Shipment• Prepare Land Disposal Restriction Form (land
ban form)– Done for all waste that does not meet the land
disposal treatment standards• Generator’s name and address• Manifest #• Description of waste
– Hazardous wastes» Example “lead”
– Underlying pollutants» Example “nickel”
Record Retention• Must keep records for three years
– Inspection logs– Training records– Spill reports– Hazardous waste manifests– Land disposal restriction forms
• Must update annually– Hazardous waste determinations
The Other Regulated Wastes
Hazardous wastes that can be managed under reduced requirements specific to the waste type
•Used Oil (40 CFR Part 279)
•Universal Waste (40 CFR Part 273)
Used Oil
“Synthetic or petroleum based oil that has been used and as a result can no longer be used without
processing”– Lube oil (gas/diesel powered equipment)– Machining (milling, drilling, grinding, broaching)– Hydraulic oil– Heat transfer fluids– Metal forming (drawing, rolling, extrusion)– Heat treating
• Includes oil contaminated materials (unless drained)– Oil filters (not drained) – Absorbents
• Does not include animal oil, vegetable oil, or waste oil
Used Oil
• Presumed to be recycled– Re-refined– Burned for energy recovery
• If not recycled, fully regulated HW– Disposed (placed on ground)– Incinerated (burned without energy recovery)
Used Oil• Can exhibit a HW characteristic or be listed HW
• Can mix with an ignitable only HW• Provided mixture does not exhibit the ignitable characteristic
• Must test for total halogens• > 1000 ppm halogens - presumed mixed with hazardous waste.
- test for halogenated solvents (100 ppm = HW)
Used Oil• Must label containers/tanks “Used Oil”
• If stored outdoors –– On an impervious base– In secondary containment
• Can be burned in a space heater
• No storage time limits
• No volume limits– If over 1340-gallons (both used and virgin) must prepare a SPCC plan
Used Oil
• Can self transport to an aggregation area– Aggregation area owned/operated by the generator– 55-gallons per trip
• If shipped off-site –– Ship off-site to facility that has an EPA Id. No.– Ship using a transporter with EPA Id. No.– Use a manifest or shipping invoice
Used Oil
• Can be sold as a fuel if “on-specification”– Needs testing to show its comparable to fuel oil
• BTU value (at least 5,000)• Arsenic 5 ppm or less• Cadmium 2 ppm or less• Chromium 10 ppm or less• Lead 100 ppm or less• Flash point 100 deg. F. minimum• Total halogens 4000 ppm or less
• Can’t be sold for residential fuel (in CT)
Questions
Universal Waste• Special rule for wastes that are universally
generated
• Are hazardous wastes (listed or characteristic)– Exception (FIFRA recalled pesticides & waste added by states)
• Can be generated anywhere– Manufacturing buildings– Office buildings– Hotels– Government buildings– Parking lots– Roadways– Schools
Universal Waste Types• Mercury containing lamps
– Fluorescent– Metal halide– Mercury vapor– Sodium vapor
• Mercury thermostats
• Batteries– Lead acid (lead and acid)– NiCad (cadmium)– Mercury cell (mercury)– Silver cell (silver)– Nickel hydride (alkali)
• FIFRA banned pesticides
Universal Waste
• States can add other waste types (HW or non-HW)– Ct added –
• Mercury containing equipment• Used electronics• All types of fluorescent lamps
Universal Waste
• No presumption of recycling
• Store for one year
• Label – “universal waste batteries”, – “universal waste lamps”, etc
• Can send to other universal waste generator
Universal Waste
• Can self transport, send through mail, etc
• Use shipping invoice if shipped by transporter
• Becomes fully regulated HW when– Disposed (such as spilled or broken)– Burned
Questions
Used oil & handling requirements
Universal Waste & handling requirements
Midnight Dumping
Midnight Dumping
• Try to determine what it is–Residential
• Milk jug• Antifreeze jug• One-gallon Paint can• Containers of less than 5-gallons
–Waste types• Oil• Antifreeze• Paint• Gasoline
Midnight Dumping
• Try to determine what it is–Commercial/business
• Several of same size containers• Five-gallons and larger• Labeling such as
– Ship to – Name of supplier– Product name– Flammable, corrosive, etc
Midnight Dumping
• Note container condition and type–Leaking–Corroded–Open–Steel, poly, fiber–Size–Shape–Labeling
Midnight Dumping
• Call Oil & Chemical Spills (860-424-3338)–Describe observations –Give location
• If leaking, secure and contain• If you feel it is safe, bring it back to your
storage area, label “midnight dumping waste”
Sources of Assistance
• DEP Compliance Assistance Phone Line– Toll free 888-424-4193– RCRA main line 860-424-3023
• David Stokes, DEP Waste Management– 860-424-3269
A Few StatisticsUnused oil – 29 million gallons spilled to ground
Used oil – 1.4 billon gallons generated300 million gallons disposed on ground
Used oil filters – 400 million generated360 million disposed on ground
Used batteries – 70 million generated14 million disposed on ground (28 million gallons acid)
Fluorescent tubes – 600 million generated120 million disposed on ground (20,000 pounds mercury)
Spent solvent – 850 million gallons generated200 million gallons disposed on ground