contingency Plan-4 pages

BEM 3701, Hazardous Waste Management 1

Course Learning Outcomes for Unit III Upon completion of this unit, students should be able to:

3. Describe various types of hazardous wastes, their impact on the environment, and respective environmental control and public health remedies.

4. Evaluate relevant regulatory compliance requirements in the industrial environment.

Reading Assignment Chapter 12: Hazardous Waste Generator Requirements Chapter 13: Hazardous Waste Transportation

Unit Lesson Hazardous Waste Generator Requirements Part of the Resource and Conservation Recovery Act’s (RCRA) cradle-to-grave regulation of hazardous waste includes the regulation of hazardous waste generators (as found in 40 CFR 262). A waste generator is responsible for determining whether the waste it generates is considered hazardous under RCRA. Generators must measure the quantity of hazardous waste (HW) generated per calendar month. This amount must include any waste that the generator accumulates on-site, waste that is treated or disposed of at the site, and waste that is collected as sludge or removed from storage tanks (Pichtel, 2014). The amount of HW generated then becomes the criteria by which a generator type is determined. The two types are large quality generator (LQG) and small quantity generator (SQG). RCRA requires that SQGs and LQGs be permitted, but the requirements of the permit for the SQG are less stringent than those for the LQG. A generator qualifies as a LQG if it generates greater than 1000 kg of hazardous waste or 1 kg of acutely hazardous waste per calendar month. A facility that generates more than 100 kg and less than 1000 kg of hazardous waste, or 1 kg of acutely hazardous waste per calendar month is considered a SQG. Generators must classify their waste to a waste code. Understanding what codes are typical for specific types of industry help waste managers to anticipate the characteristics of the waste stream for their facility. One additional category of waste generator is the conditionally exempt SQG (CESQG). A CESQG is a facility that generates less than 100 kg of hazardous waste or 1kg or less of acutely hazardous waste per month. These facilities are exempt from most of RCRA’s hazardous waste requirements. SQGs must comply with less stringent requirements than LQGs. Both types of facilities must obtain an EPA Identification Number. LQGs are allowed to accumulate hazardous waste on site in containers, containment buildings, or tanks for up to 90 days without a permit. Each container must be marked with the date on which the accumulation of the waste began. If these wastes must be stored for more than 90 days, the facility qualifies as a treatment, disposal, and storage facility (TSDF), and the facility is then subject to additional regulation (found in 40 CFR 264 and 270). Even if the waste is not accumulated for more than 90 days, there are requirements regarding how the waste is stored in the container or tank at an SQG or and LQG. For example, the tanks or containers must be labeled with the words “Hazardous Waste” and the date the waste was generated. There are several other specific requirements that cover where the waste is stored, inspection requirements, and maintenance requirements. In addition to tanks and containers, RCRA allows waste to be stored, under limited circumstances, in piles in containment buildings. The facility must have a permit to do

UNIT III STUDY GUIDE

Hazardous Waste Generator Requirements

and Hazardous Waste Transportation

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so, and there are several requirements that must be met. These requirements include certification of the building by a professional engineer and a routine inspection (Pichtel, 2014). Emergency Response Requirements An LQG must prepare a written emergency response plan, and it must provide hazardous waste management and emergency response training to its employees. The plan must be filed with the police and fire department, hospitals, and emergency response teams. The LQG must also have a designated employee who is responsible for emergency response measures. SQG emergency response requirements are not as stringent. The SQG must still have an employee designated as responsible for emergency response. A full emergency response plan is not required, however. The SQG does have to post emergency response information next to office phones and familiarize its employees with emergency procedures. Hazardous Waste Transportation The tracking and regulation of hazardous waste does not stop with its generation. When an SQG or LQG transports waste off-site for disposal or treatment, it is closely tracked by the Environmental Protection Agency (EPA). There are Department of Transportation Regulations that apply, as well. Consider the quantity and frequency of transport of hazardous waste. In 2010, over 16,000 shippers transported about six million tons of hazardous waste (HW). More than half of the HW shipped in 2010, was shipped across state lines (Pichtel, 2014). There is a split of authority in regulation of various aspects of transport of hazardous waste between the Department of Transportation (DOT) and the Environmental Protection Agency (EPA), whereby DOT has traditionally regulated hazard identification, packaging and transport of all chemicals including wastes. EPA regulations (RCRA, Subtitle C) cover the management of those shipments and tracking of their quantities, as well as certain activities performed in preparation of the shipments and recordkeeping requirements. There are various ways in which hazardous waste is transported across the United States. Cargo tanks are the main carriers, but almost 155 million tons of hazardous waste is transported by rail each year (Pichtel, 2014). The DOT regulates tank car design and rail car design for hazardous materials transportation. Generally, transporters are either generators who are transporting their waste to a TSDF, contractors who are collecting waste from generators and then hauling to a TSDF, or TSDFs that are collecting waste from generators. Each transporter must use the Hazardous Waste Manifest System. The manifest documents the type and amount of waste, waste handling instructions, and signature lines for each party involved in the disposal of the waste. As part of the DOT’s hazard communication regulations, the hazardous waste shipper must comply with regulations for the waste’s “identification, classification, labeling, packaging, markings, placards, and shipping documentation” (Pichtel, 2014, p. 406). The information must be available to the public, emergency response teams, and regulators. In the event of a spill, the identification of the hazardous waste allows emergency responders to take appropriate measures to protect themselves, as well as the public. The Hazardous Materials Table, which is found in 49 CFR 172.101 (see the Learning Activity in Unit II for instructions on how to find this section of the regulations), lists the materials regulated as hazardous by the DOT. The table lists all of the information one would need to transport the waste. In the DOT regulations, hazardous waste is considered a subset of hazardous materials, which are subject to additional regulations (Pichtel, 2014). Perhaps you have noticed the placards on tractor-trailers as you drive down the highway. Each of these placards contains important information regarding the type of waste that is being transported. There are various classes of hazardous materials, and each class has its own placarding and marking requirements. Hazardous materials are classified as explosive gases, flammable liquids, flammable solids, oxidizers and organic peroxides, toxic or poisonous materials, radioactive materials, corrosive materials, miscellaneous hazardous materials, and other regulated materials (Pichtel, 2014). In the event of a hazardous materials spill, 49 CFR 171.15 requires that transporters notify the National Response Center immediately of any significant hazardous materials incident during transportation. The incident must meet a certain set of criteria to be considered immediately reportable. For example, the incident must be immediately reported if a person is killed or an evacuation of more than one hour occurs (Pichtel, 2014). When these incidents occur, the hazard communication regulations are invaluable for protecting worker safety and public health. For example, if a tractor-trailer overturns and emergency responders see that

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a placard indicates that the material the truck was carrying is poisonous and gaseous, they know that they must wear proper protective equipment, and potentially evacuate the area.

Reference Pichtel, J. (2014). Waste management practices: Municipal, hazardous, and industrial (2nd ed.). Boca Raton, FL: CRC Press.

Suggested Reading The website presented below provides a searchable database enabling the user to identify RCRA-related information. Go to the website and click on “Topics Search.” http://www.epa.gov/epawaste/inforesources/online/index.htm