Hazardous Waste Training Dawn Lee, Chemical Hygiene Coordinator for the Sciences x 5873 [email protected] www.brockport.edu/chemsafe Who Needs Training? Any Faculty, Staff, Student or Volunteer who is responsible for generating waste determining what is or is not haz waste (& how to dispose) transporting haz waste (SAACAA) inspecting haz waste storage areas responding to spills involving haz waste Extent of training depends on responsibilities Governing Agencies Federal - US EPA (Title 40 CFR) www.gpoaccess.gov/ecfr (Title 40, Parts 260-265) State - NYS DEC (6 NYCRR) http://www.dec.ny.gov/regs/2491.html (370 series) Local - Monroe County Water Authority http://www.monroecounty.gov/p/pw-RulesAndRegulations.pdf http://www.monroecounty.gov/p/pw-SewerUseLaw.pdf Solid Waste 1. Discarded or Abandoned material that may be: Solid, Semisolid, Liquid or Gas “Discarded” or “Abandoned” “Thrown away” due to being spent, contaminated, or unwanted Burned or incinerated Accumulated, stored or treated in lieu of disposal/burning or before recycling 2. Recycled Reclaimed – recovery of usable product; regeneration Reused – used as ingredient in secondary process Exemptions: Direct use/reuse – used as an ingredient without first being reclaimed Product substitution – the material acts as a viable product without first being reclaimed Return to production process – reintroduction at any point of the production process without first being reclaimed 2. Recycled cont’d Direct placement on land (unless that is its intended purpose) Burn directly or use to produce fuel (unless the chemical is intended to be a fuel) Make usable again Use Constituting Disposal (1) Energy Recovery/ Fuel (2) •No viable market •Can’t recycle 75% in a calendar year Reclamation (3) Speculative Accumulation (4) Spent materials (*) (*) (*) (*) Sludges listed in 371.4(b) and (c) (*) (*) (*) (*) Sludges exhibiting a characteristic of hazardous waste (*) (*) -- (*) By-products listed in 371.4(b) and (c) (*) (*) (*) (*) By-products exhibiting a characteristic of hazardous waste (*) (*) -- (*) Commercial chemical products listed in 371.4(d) (*) (*) -- -- Scrap Metal other than excluded scrap metal (see 371.1(a)(9) (*) (*) (*) (*) Solid Waste cont’d 3. Inherently Waste-Like Industry specific and dioxins Halogen acid furnaces 4. Military Munitions Solid Waste Exclusions Domestic sewage Scrap metal The rest is fairly industry specific If you plan to use an exclusion or an exemption to recycle, you must notify the NYSDEC Hazardous Waste A solid waste that can pose a substantial or potential hazard to human health or the environment when improperly managed Determined at Point of Generation to have at least one of four characteristics Ignitability (D001) Corrosivity (D002) Reactivity (D003) Toxicity (D004-D043) and/or appear on special EPA lists (F, K P, U) Haz Waste: Ignitability A liquid with a Flash Point < 140º F (60°C) Flash Point - lowest temperature at which a liquid has a vapor pressure that forms an ignitable mixture with air near the surface of the liquid • Lower Flash Point Greater Hazard Exception: Aqueous alcohol < 24% Non-liquid capable of causing fire thru friction, absorption of moisture, or spontaneous chemical change and when ignited, burns vigorously Ignitable compressed gases Certain strong oxidizers – able to donate or promote oxygen (chromates, nitrates, permanganates, perchlorates, peroxides, etc.) Haz Waste: Ignitability Examples Many organic solvents (acetone, toluene, ether, xylenes, methanol, ethanol, etc.) Fuels such as gasoline and kerosene Oil-based paints Acetylene gas Pyrophoric chemicals (some fine metal powders, phosphorus, some organometallics, metal & non-metal hydrides, etc.) Haz Waste: Corrosivity Must be liquid and have pH 2 or 12.5 Sewer ordinance pH 5.5 or 10 “Elemental Neutralization” - change pH for disposal is allowed Part of the experiment/lab procedure/SOP Bulk neutralization (initially stored) 6NYCRR 373-1.1(d)(1)(xii) – elemental neut. 6NYCRR 373-1.1(d)(1)(ix) – treatment in containers Haz Waste: Corrosivity Examples: Any high or low pH-cleaning products Sulfuric acid (Battery acid) Hydrochloric acid (Muriatic acid) Acetic acid (Vinegar) Nitric acid Chromic acid ** Sodium hydroxide Ammonia solutions (Ammonium hydroxide) Haz Waste: Reactivity Normally unstable or explodes with or without detonation Reacts violently with water, air, or heat Generates toxic gases when reacted with water CN-1 or S –2 which liberate toxic gas in acidic or basic conditions May not be labeled as reactive when new (become reactive with time) Reactivity Water Reactive – reaction with water releases toxic gases, heat, O2 or H2 (CN-1 and S-2 salts, IA & IIA metals (Li, Na, K, Ca), organometallics, adding acids/bases, etc.) Pyrophore - ignites with air contact (finely powdered Zn, Mg, P, C, some organometallics, etc.) Unstable liquid - polymerize, decompose, or become self-reactive under conditions of shock, pressure, or temperature (styrene, vinyl chloride, etc.) Explosive – goes boom (C=C, C-N, nitro groups, azides, metal-N bonds, epoxides, etc.) – Dryness sensitivity (dry picric acid, NI3, organic peroxides) – Auto-oxidizers (peroxide formers) Auto-oxidation – Formation of Explosive Peroxides • Most common: Diethyl ether MIBK Furan Alkenes Isopropanol THF General Info on Peroxide formation http://www.ilpi.com/msds/ref/peroxide.html • Stabilizers/inhibitors often added (free radical scavengers) • Date upon receipt and when opened • Test for peroxide formation every 3-6 months – test strips available. • Adhere to Expiration Dates • Concentrating procedures such as evaporation or distillation. • Sources of Friction…unscrewing a lid, popping out a glass stopper, grinding solids with glass rods or spatulas Mixing Wastes: Reactive Issue Prevention Golden Rules – segregate incompatibles! • • • • • oxidizers from everything! (inc. HOAc & HNO3) acids and bases acids and metals corrosives and organics flammables and reactives Toxicity Fails the TCLP (lab test) : when the waste contains specified contaminants the table values (they will leach at a landfill) D-listed waste with a ppm/ppb level Heavy metals Organic chemicals B list = only in NY, PCBs 50 ppm is hazardous waste Listed Wastes • F list – waste from non-specific sources (F001-F005 spent solvents) – 10% or more of any one or combo of the 31 solvents listed before use – Used for solvent properties • K list – waste from specific sources (industry) • P & U lists – unused chemicals that are deemed toxic or acutely toxic (pure or in mixture) Listed Wastes In addition to F, K, P, U codes, you may find: (I) - ignitable (C) – corrosive (R) – reactive (E) – toxicity characteristic (D-list) (T) – toxic (U-listed and appendix VIII) (H) – acutely toxic (P listed) Listed Wastes P08 155–63–0 Nitroglycerine (R) U002 U006 67–64–1 75–36–5 Acetone (I) Acetyl chloride (C,R,T) F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1trichloroethane, carbon tetrachloride, and chlorinated fluorocarbons; all spent solvent mixtures/blends used in degreasing containing, before use, a total of ten percent or more (by volume) of one or more of the above halogenated solvents or those solvents listed in F002, F004, and F005; and still bottoms from the recovery of these spent solvents and spent solvent mixtures (T) Is it Hazardous Waste? 1. Is it solid waste (by RCRA definition)? 2. Is it on one or more of the RCRA/DEC lists? 3. Does it exhibit one or more of the characteristics of ignitability, corrosivity, reactivity, or toxicity? 4. What if it does not fall on a list or in any of the characteristic waste definitions? How to dispose? • ethidium bromide • solid sodium hydroxide • known or suspected carcinogens or reproductive toxins Mixture & Derived-from Rules for Listed Wastes Mixture rule - if you mix a listed hazardous waste with non-hazardous waste, it’s ALL hazardous Spill materials Filter aids Derived-from rule – if a listed hazardous waste is treated or changed in some way, the new waste is considered hazardous Once listed, always listed! Mixture & Derived-from Rules for Characteristic Wastes Mixture rule – only hazardous if it still exhibits the hazardous characteristic Derived-from rule – product is only deemed hazardous if it exhibits a hazardous characteristic This includes “listed” materials that are listed strictly due to characteristic Treatment can be done to render non-hazardous Limitations without permitting Certain recycling processes Elemental Neutralization Other Information Absolutely NO disposal of hazardous materials in trash, down the drain, or by evaporation Waste oil w/ no solvent can be tested & recycled Samples for testing are exempt while collecting and shipping RCRA Empty For Non-Acutely Hazardous Materials, A container is RCRA empty when: All wastes removed (poured, pumped or aspirated) and no more than 1” of non-removable material remains on the container bottom or no more than 3% by weight of the total capacity of the container remains (containers smaller than 119 gallons) RCRA Empty Acutely Hazardous Materials: Triple-rinse with appropriate solvent (treating all rinses as haz waste) Compressed gas cylinders: Are “empty” when internal pressure approaches 1 atm Labware considered “empty” is NOT haz waste Packaging Hazardous Waste Containers MUST be • In good condition (no leaks, bulges, rust, etc.) • Compatible with the waste being stored in them, as well as holding only compatible waste streams • KEPT CLOSED except when adding or removing waste. • Labeled appropriately – “Hazardous Waste” • Free of residual around caps and outside of bottles • Handled & stored in a manner that prevents potential exposure to the environment (2º containment) • Compliant with air emission standards Packaging Hazardous Waste Containers SHOULD be • large enough to hold the waste being generated, yet small enough so the container can be filled quickly & removed • filled only to a level that allows for some head space for vapor expansion Labeling Hazardous Waste All hazardous waste containers MUST be labeled with: The words “Hazardous Waste” The contents of the container Chemical names - not symbols, acronyms, or structures (unless a key is readily available) Mixtures need to have a list of approximate quantity/concentration of each component The hazards associated with contents (toxic, flammable, etc.) Date that accumulation started (in central storage- not in SAA) Contact info for responsible party (PI, Lab Manager, etc.) Hazardous Waste Tags HAZARDOUS WASTE Print Your Name:_______________________ Bottle Code___________ Building & Room No.________ Total Amount in Container:__________ Container Size:_________Dept:________________ Phone:_________ COMPLETE CHEMICAL COMPOSITION: (List approximate % of each constituent including water/solvent) 1. ____________________________% 6. ___________________________% 2. ____________________________% 7. ___________________________% 3. ____________________________% 8. ___________________________% 4. ____________________________% 9. ___________________________% 5. ____________________________% 10.___________________________%. Check if applicable: __ Flammable __ Corrosive (pH ___) __ Oxidizer __ Highly Toxic ___ Stench __ Reactive (__ Water___Shock ___Other ______________) To the best of my knowledge, I certify the information provided is accurate and the hazardous waste generated has been minimized. Sign & date when moved to Central Storage. Sign Name:___________________________________ Date:_____________ Mixed Haz Waste Manifest (pg. 1) Hazardous Waste Organic Liquid Flammable General Contents: For EXACT composition, refer to log sheet _______ Room: Satellite Accumulation Start Date: Mixed Haz Waste Manifest (pg. 1) Organic Liquid Hazardous Waste Only SUNY College at Brockport Room ________ Date Generated Name of Person Responsible______________ Bottle Code_____ Chemical Composition Volume Signature Date Bottle Filled:______________________Total Volume:_________________ Date Bottle Removed to Central Storage:_________________ Mixed Haz Waste Manifest (pg. 2) Please attach this sheet to the hazardous waste bottle upon removal to Central storage. The detailed profile should be retained by the faculty member/department. Summary of Hazardous Waste Profile: *Hazardous characteristic categorized as ignitable, corrosive, reactive, toxic, acute hazard or other special traits such as oxidizer or poison Total Volume Chemical Room Collected: __________ Name of Person Responsible______________________ Date Bottle Filled:____________ Hazardous characteristic(s)* Total Volume:_________________ Date Bottle Removed to Central Storage:__________ Satellite Accumulation Storage Requirements Place where wastes are generated and stored prior to moving to central accumulation area: Must be stored in the same room it is generated May accumulate up to 55 gal of haz waste (all types collectively) or up to 1 qt. of acutely hazardous waste Must be under the control of the person that created it There are no time limits on accumulation times SAA Follow all appropriate container management regulations: Labeling (“Hazardous Waste”) Good condition Closed containers Compatibility If 55 gallons or 1 quart P-listed container is full, must date and remove to Central Accumulation Area (CAA) within 3 days Categories of Generators Conditionally exempt small quantity (CESQG) Less than 100 kg/month or 1 kg acute Small Quantity Generator (SQG) Between 100 kg and 1,000 kg /month Large Quantity Generator (LQG) More than 1,000 kg/month or 1 kg acute Count all generated except: exemptions, immediate elementary neutralization, immediate recycling, oil, lead-acid batteries and Universal Waste CESQG Requirements Must determine hazardous waste Never store more than 1000 kg total or 1 kg acute – no time limits May treat or dispose on site or regulated offsite facility Monroe County Department of Environmental Services will work with CESQG SQG Requirements Must have EPA ID# Must determine hazardous waste Up to 6000 kg for 180 day storage (270 days if TSDF is 200 miles away) Proper container & tank maintenance, including labeling and compatibility Preparedness & Prevention Plan Less stringent “Contingency Plan” Manifest LQG Requirements Must have EPA ID# & determine waste 90 day storage Proper container & tank maintenance, including labeling and compatibility TRAINING and documentation yearly as appropriate to job function A variety of plans and manifests needed for compliance Weekly inspections of CAA Storage Security • • • • Practical & legal issues Lock doors when no one is in the area Limit key distribution Particularly hazardous chemicals – 2° security Ways to minimize hazardous waste Updated inventory Don’t buy what you already have Don’t buy more than you need Sharing within a business, but not outside Microscale Legal treatment options Penalties Penalties for non-compliance: Warning – no fine Civil Penalties ($32,500 per violation/day) Company Individual Criminal Penalties (malicious intent - $50k) Individual Company Websites • EPA Training Modules http://www.epa.gov/osw/inforesources/pubs/hotline/rmods.htm • EPA RCRA User-Friendly Reference Guide http://www.epa.gov/osw/hazard/downloads/tool.pdf
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