HAZARDOUS WASTE

Do you know how to comply with federal hazardous waste regulations?

Do you know what is considered hazardous waste?

Wastes are considered hazardous if they appear on one of four lists

published in the Code of Federal Regulations.

There are currently more than 500

wastes listed because they are known to be harmful to human health and

the environment.

A material may be hazardous even if it doesn’t appear on the lists if it:Is an ignitable waste (paints, degreasers and solvents)Is a corrosive waste (rust removers, acid cleaning fluids and battery acid)Is reactive waste, meaning it is unstable and explodes or produces toxic fumes, gases and vapors when mixed with water or placed under heat or pressure (cyanides or sulfide-bearing wastesIs a toxic waste, meaning it is harmful or fatal when ingested or absorbed or leaches toxic chemicals into the soil or ground when land filled (cadmium, lead or mercury)

Typical Wastes Generated

Type of Business How Generated Typical Wastes

Construction Paint prep and painting, floor work, heavy construction and construction vehicles

Ignitable wastes, paint wastes, acids/bases

Laboratories Diagnostic and other lab testing Spent solvents, unused reagents, reaction products, testing samples, contaminated materials

Vehicle Maintenance

Degreasing, rust removal, paint prep, tank cleanout, installation of lead-acid batteries

Acids/bases, solvents, ignitable wastes, paint wastes

Equipment Repair Degreasing, cleaning, painting Acids/bases, toxic wastes, ignitable wastes, paint wastes, solvents

PCB’S (Polychlorinated Biphenyls)

• Hazardous Waste ?• PCBs are not hazardous waste under federal

regulations, although many of the management requirements are similar to those for hazardous wastes. Some states, however, choose to include PCBs in their Resource Conservation and Recovery Act (RCRA) hazardous waste programs. Therefore, management and disposal of PCBs in these states are subject to requirements of both TSCA (Toxic Substances Control Act of 1976) and RCRA.

PCB’s What are they?

• PCBs are a family of over 200 organic compounds. They vary from mobile, oily liquids to white solids, or resins. PCBs demonstrate a high degree of chemical stability, high boiling points, low flammability, and low electrical conductivity. These properties made PCBs attractive for many high-temperature and electrical insulating applications. However, these same properties cause PCBs to remain in the environment for a long time. PCBs accumulate throughout the food chain, and EPA considers them carcinogens.

What are Polychlorinated BiphenylsWhat are Polychlorinated Biphenyls

• Synthetic Organic Chemicals

• Carcinogens

• Teratogens

• No taste nor smell, colorlesscolorless to light yellow

What are PCB used for?

• Coolants

• Lubricants

• Transformers

• Capacitors

• Insulators

Where are they currently?Where are they currently?• Mostly in light ballastsMostly in light ballasts• TransformersTransformers• Old appliancesOld appliances• An IDEA on how to manage PCB’s

• IIdentify all potential PCB’sdentify all potential PCB’s• DDevelop a plan to manage PCB’sevelop a plan to manage PCB’s• EEliminate leaky PCB materialliminate leaky PCB material• AAsses environmental impactsses environmental impact

PCB Classifications

• Regulation of PCBs and PCB-containing materials derives from the concentration of PCBs in a material. Below 50 parts per million PCBs, the material is “non-PCB.” Between 50 and 500 parts per million PCBs, the material is “PCB-contaminated.” Above 500 parts per million PCBs, the material is a PCB.

Identify

Label accordingly

Manage PCBsInspect every 3 monthsKeep logs of inspectionsWhen removed from service, make record & keep with inspection log

Eliminate Damaged PCB Material

• Keep PCB containing material in a approved container

• Dispose of within 1 year

Access the Damage

• Spill plan in place

• Emergency plan in place

• Disposal equipment & plan in place

• Records kept and available

• Personnel trained on what to do

Plan for PCBs

• Check transformers for leaks every 3 Check transformers for leaks every 3 months.months.

• Storage container checked for leaks every Storage container checked for leaks every 30 days.30 days.

• If storing over 99.4 lbs., must have a If storing over 99.4 lbs., must have a annual document log and records of annual document log and records of disposal of PCBs and PCB itemsdisposal of PCBs and PCB items

• Item-by-Item Instructions for Completing EPA Form 7720-12

• Return completed form to:

• Fibers & Organics Branch (7404T)

• Office of Pollution Prevention & Toxics

• U.S. Environmental Protection Agency

• 1200 Pennsylvania Ave., N.W.

• Washington, DC 20460-0001

• FAX – 202-566-0473

• PCB Transformer means any transformer that contains 500 ppm or greater PCB dielectric. For PCB concentration assumptions

• applicable to transformers containing three pounds or more of fluid other than mineral oil, see 40 CFR 761.2. For provisions

• permitting reclassification of electrical equipment containing 500 ppm or greater PCBs to PCB-Contaminated Electrical

• Equipment, see 40 CFR 761.30(a) and (h).

• Type or print in black ink all items, except Item 3, “Certification.” If you must use additional sheets, indicate

• clearly the number of the item on the form to which the information on the separate sheet applies.

• Item 1 Company Name: Enter the name of the company which owns the equipment.

• Address: Enter the street, city, state, and zip code of the company.

• Contact Name and Phone Number: Enter the name and business telephone number of the person

• who should be contacted regarding information submitted on this form.

• Item 2a Location of PCB Transformers: Enter the address (street, city, state, and zip code) where the PCB Transformer(s) is

• located. Please note that the address you give must be a physical address, not a P.O. Box. Route numbers are acceptable provided

• they include enough specificity to assist emergency response personnel in determining the location of the transformer(s).

• Item 2b Number (No.) of Transformers and weight (wt..): Enter the total number of PCB (500 ppm or greater) Transformers

• at this location (address) and the total weight (wt..) in kilograms (kg) of the PCB dielectric fluid in the transformer(s).

• Item 2c Any transformers containing flammable dielectric fluid: (Response optional) Circle yes or no if you have any

• knowledge that there are or are not transformers at this location (address) that contain flammable (see 40 CFR 261.21(a)(1) -

• Characteristics of Ignitability) dielectric fluid.• ***Please note this form has been designed to accommodate companies submitting registrations for multiple

locations. However,• companies with more than 4 locations may choose to submit an additional form(s) or an attachment(s).• Item VII -- Certification: This certification must be signed by the owner, operator, or an authorized

representative of the• transformer owner or operator of the facility or property where the unit is located. An “authorized

representative” is a person• responsible for the overall operation of the facility (i.e., a plant manager or superintendent, or a person of equal

responsibil ity).• All notifications must include this certification to be complete.• EPA Form

• TO REGISTER YOUR TRANSFORMERS THAT CONTAIN PCB’S GREATER THAN 500 PPM

• GO TO EPA WEB SITE AND REQUEST FORM 7720-12

Spill Plan for PCBsSpill Plan for PCBs• Phones numbers to NRC & EPA• Phone number to an authorized disposal

contractor • Keep a PCB disposal container on site• Laboratories in the area that test for PCBs• National Response CenterNational Response Center • 1-800-424-8802• EPAEPA• if over 10 lbs.

PCB’s

• Check you state regulations to see if PCB’s fall under RCRA as well as TSCA.

• REMEMBER DON’T ASSUME, IT WILL GET YOU IN TROUBLE EVERY TIME.

The EPA has defined three categories of hazardous waste generators:

1. Conditionally exempt

2. Small quantity generators

3. Large quantity generators

Conditionally exempt small quantity generators generate less

than 220 pounds of hazardous waste per month

• Reminder: MOST OF OUR FACILITIES ARE CONDITIONALLY EXEMPT SMALL QUANTITY GENERATORS AND SHOULD LOOK CLOSELY AT THE REGULATIONS THAT PERTAIN TO THAT STATUS

Small quantity generators generate between 220 pounds

and 2,200 pounds of hazardous waste per month.

Large quantity generators generate more than 2,200

pounds of hazardous waste per month.

Requirements for Conditionally Exempt Small Quantity

Generators

Identify all hazardous material that you generateYou may not store more than 2,200 pounds of hazardous waste on site at any given time.Ensure that delivery of hazardous waste is:

ØTo an off-site treatment or disposal facility that is state or federally regulated for treatment, storage or disposalØTo a facility permitted, licensed or registered by a state to manage municipal or industrial solid wasteØTo a facility that uses, reuses, or legitimately recycles the wasteØTo a universal waste handler or destination facility subject to the requirements of 40 CFR Part 273

REVIEW

Identify your hazardous wasteIncluding proper storage and labeling

Comply with storage quantity limits

Ensure proper treatment and disposal of your waste

Requirements for Small Quantity Generators

If you generate between 220 and 2,200 pounds of hazardous waste per

month, you are a Small Quantity Generator.

To be compliant with requirements, you must:

Obtain and use an EPA Identification Number.

Obtain a copy of EPA Form 8700-12, Notification of Hazardous Waste Activity

Fill in the form completely. Be sure to sign the certification at

Item “14”. Note that state forms may contain additional

sheets

Send completed forms to your state hazardous waste contact listed in the information booklet (You will receive this along with the form.)

MANAGING HAZARDOUS WASTE ON SITE

Small Quantity Generators can accumulate no more than 13,228 pounds of hazardous waste on site without a permit. You can accumulate this amount of waste for up to 180 days (270 days if you must transport it more than 200 miles for disposal, treatment or recovery.

Small Quantity Generators must accumulate wastes in tanks or containers, like 55 gallon drums. All containers must:

Be labeled “HAZARDOUS WASTE” and include the date that waste was initially generated

Be made of a material that is compatible with the hazardous waste being stored. This prevents corrosion or reactivity

Be kept closed during storage, except when adding or removing waste

Be kept in good condition. Inspect storage areas regularly to look for leaks and deterioration

And probably the most important rule to follow with Hazardous Waste storage is:

DO NOT MIX WASTE MATERIALS. IT CAN

CREATE AN UNSAFE WORK ENVIRONMENT AND LEAD TO MORE COMPLEX AND EXPENSIVE CLEAN-UPS.

The Better Way…Waste Minimization

Do not mix wastes to create new wastes

Change materials, processes or both

Recycle and reuse manufacturing materials

Safely store hazardous products (prevent spills/leaks)

Make a real effort to minimize waste generation

Shipping Waste Off-Site

Small Quantity Generators may send their waste only to a regulated Treatment,

Storage and Disposal Facility (TSDF). Check with your state authorities to be sure

your facility has all necessary permits.

Package, label and mark your shipmentPrepare a hazardous waste manifest to accompany your shipmentMaintain copies of all manifests for lifeInclude a notice and certification with the first waste shipmentEnsure the proper management of any hazardous waste shipments you make

When selecting a hazardous waste transporter or TSDF/Recycler…

Talk to colleagues and/or competitors to see who they are using

Talk to reps at trade shows Check with the Better Business BureauAsk your state agencies if transporters /

recyclers have an EPA number

When you are sending out wastes, make sure that you always get a copy of the shipping manifest.

You are responsible for the materials even when they leave

your property. Fill out the manifest completely and

accurately.

LARGE QUANTITY GENERATORS

If you generate more than 2,200 pounds of hazardous

waste monthly, you are subject to the full set of

hazardous waste regulations.

These include, but are not limited to:

Determining amounts of waste generated

Applying for an EPA Identification Number

Preparing waste for shipment and filling out manifests

Accumulating waste no more than 90 days, without a permit

Preparing a biennial report

If applicable, monitor air emissions