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PollutionEngineering November 2012 : Page 14

10 COMMON QUESTIONS for Waste Generators When it comes to hazardous waste handling, there are 10 questions every environmental manager should be able to answer. By: Karen Hamel, Technical Writer for New Pig Corp . What is missing in the above photo? The liquid being added is not known. But, at the least, gloves should be worn. It might also be a good idea to include a full-face mask to avoid getting splashed. F acilities are required to make solid and hazard-ous determinations for all wastes generated at their site. When wastes are deter-mined to be hazardous, the Resource Conservation and Recovery Act (RCRA) requires processes and plans in place to safely manage these wastes in a manner that minimizes their potential to harm people and the environment. When properly designed, the infor-mation in these plans serves as a tool to help workers manage wastes safely, as a resource for responders handling spills, and as a guide for individuals perform-ing reporting functions. Environmental managers should be knowledgeable about the amounts and types of wastes generated at the facility, as well as their storage, handling and disposal. Including answers to the fol-lowing questions in facility contingency plans can help increase knowledge and compliance. 14 Pollution Engineering NOVEMBER 2012 1. Is the waste properly stored and labeled? Hazardous wastes must be stored in containers or tanks that are in good condi-tion and compatible with the wastes being stored. A properly marked container will have the words “hazardous waste” writ-ten, stenciled or otherwise clearly marked on it as well as the accumulation start date. When the container will be shipped offsite for recycling or disposal, it must also be marked with the applicable DOT markings (40 CFR 262.31), the generator’s name, address, EPA identification number and the manifest tracking number. Waste containers must be kept closed (40 CFR 264.173) and inspected weekly (40 CFR 264.154) to help ensure that wastes are not stored beyond their 90, 180 or 270 day time limits (40 CFR 262.34) and that no containers are damaged or leaking. Providing containment (40 CFR 264.175) for hazardous waste contain-ers is also required and minimizes the potential for spills to be released into the environment. Establishing processes for proper storage and marking of containers can often be combined with other good housekeeping practices at the facility. 2. What is the facility’s EPA identifica-tion number? Under RCRA, small and large quantity generators of hazardous waste are required to submit an initial notification and obtain a site-specific EPA Identification Number (40 CFR 262.12). This number is used by the agency to track the amount of hazard-ous waste being generated by the facility, as well as disposal methods being used. It is a permanent number that remains with the facility. If ownership or contact infor-mation changes, those changes should be communicated to the EPA, but the facility identification number remains the same. The number is also used on hazardous waste manifests. Conditionally Exempt Small Quantity Generators are those who generate less than 220 pounds of hazardous waste, or less than 2.2 pounds of acute hazardous

10 Common Questions For Waste Generators

Karen Hamel

When it comes to hazardous waste handling, there are 10 questions every environmental manager should be able to answer.<br /> <br /> What is missing in the above photo? The liquid being added is not known. But, at the least, gloves should be worn. It might also be a good idea to include a full-face mask to avoid getting splashed.<br /> <br /> Facilities are required to make solid and hazardous determinations for all wastes generated at their site. When wastes are determined to be hazardous, the Resource Conservation and Recovery Act (RCRA) requires processes and plans in place to safely manage these wastes in a manner that minimizes their potential to harm people and the environment.<br /> <br /> When properly designed, the information in these plans serves as a tool to help workers manage wastes safely, as a resource for responders handling spills, and as a guide for individuals performing reporting functions.<br /> <br /> Environmental managers should be knowledgeable about the amounts and types of wastes generated at the facility, as well as their storage, handling and disposal. Including answers to the following questions in facility contingency plans can help increase knowledge and compliance.<br /> <br /> 1. Is the waste properly stored and labeled?<br /> <br /> Hazardous wastes must be stored in containers or tanks that are in good condition and compatible with the wastes being stored. A properly marked container will have the words “hazardous waste” written, stenciled or otherwise clearly marked on it as well as the accumulation start date. When the container will be shipped offsite for recycling or disposal, it must also be marked with the applicable DOT markings (40 CFR 262.31), the generator’s name, address, EPA identification number and the manifest tracking number.<br /> <br /> Waste containers must be kept closed (40 CFR 264.173) and inspected weekly (40 CFR 264.154) to help ensure that wastes are not stored beyond their 90, 180 or 270 day time limits (40 CFR 262.34) and that no containers are damaged or leaking.<br /> <br /> Providing containment (40 CFR 264. 175) for hazardous waste containers is also required and minimizes the potential for spills to be released into the environment. Establishing processes for proper storage and marking of containers can often be combined with other good housekeeping practices at the facility.<br /> <br /> 2. What is the facility’s EPA identification number?<br /> <br /> Under RCRA, small and large quantity generators of hazardous waste are required to submit an initial notification and obtain a site-specific EPA Identification Number (40 CFR 262.12). This number is used by the agency to track the amount of hazardous waste being generated by the facility, as well as disposal methods being used. It is a permanent number that remains with the facility. If ownership or contact information changes, those changes should be communicated to the EPA, but the facility identification number remains the same. The number is also used on hazardous waste manifests.<br /> <br /> Conditionally Exempt Small Quantity Generators are those who generate less than 220 pounds of hazardous waste, or less than 2.2 pounds of acute hazardous Waste per month, and store no more than 2,200 pounds of hazardous waste, or 2.2 pounds of acute hazardous waste, onsite at any time. These entities do not need to obtain EPA identification numbers; however, some choose to obtain an identification number to manage shipments or to facilitate transportation and disposal of their hazardous wastes.<br /> <br /> 3. Who are the waste shippers and TSDFs?<br /> <br /> Hazardous material transporters and Transportation, Storage and Disposal Facilities (TSDFs) play important roles in the “cradle-to-grave” liability of hazardous wastes. Hazmat employees, transporters and employees at TSDFs must be properly trained to identify and handle hazardous materials. Transporters and TSDFs are also required to have their own EPA identification numbers. Drivers contracted to transport hazardous materials must have the appropriate certifications or endorsements, and transportation companies should be adequately insured. As transportation regulations evolve, and when security of a shipment is critical, the ability to track shipments may be another important consideration for some facilities.<br /> <br /> Because TSDFs are treating and disposing of hazardous wastes, assuring that the chosen facility has the proper permits, adequate insurance and a strong compliance record are important considerations.<br /> <br /> Listing the contact information for transporters and TSDFs, and keeping copies of contracts and agreements in the facility’s Contingency Plans, helps some coordinators keep track of the information and encourages its evaluation when the entire plan is reviewed.<br /> <br /> 4. Where are the past three years of shipping manifestskept?<br /> <br /> Manifests provide detailed information about the types and volumes of hazardous materials that are shipped from a facility. The EPA requires these documents to be kept for three years (40 CFR 262.40). The information in these documents can be useful for individuals filling out biennial reports.<br /> <br /> It is important to keep complete records of all hazardous material shipments. If a copy of a signed manifest is not received within 30 days from the time that the waste was accepted by the initial transporter, the waste generator must contact the transporter and TSDF to obtain a replacement copy. If this fails to resolve the issue, an exemption letter must be filed with the EPA.<br /> <br /> 5. Are all employees who handle hazardous materials properly trained and documented?<br /> <br /> Persons who prepare hazardous materials for shipping; prepare, sign or review paperwork; load trucks; drive vehicles; receive shipments or otherwise perform a function related to hazardous materials shipment are “hazmat employees” and must receive general awareness, function specific, safety and security training. A hazmat employee is defined in the Department of Transportation regulations at 49 CFR 171.8. <br /> <br /> Hazmat employee training must occur before the employee is permitted to perform any function (except under direct supervision of another trained hazmat employee), and recurrent training is required at least once every three years. This training is sometimes combined with other required regulatory trainings. Documentation of training may be kept with contingency plans or with other employee training records.<br /> <br /> 6. Who is the designated emergency coordinator?<br /> <br /> Contingency plans must include the name of the emergency coordinator (40 CFR 264.55). This person must be on call and available to respond to emergencies; be familiar with the facility, response plans and locations of records; have the authority to carry out the provisions of the facility’s contingency plan; and be able to commit resources that may be needed.<br /> <br /> In addition, this person must be able to activate alarms when there is an emergency; contact local and state authorities for assistance when needed; assure that wastes are properly handled, treated and disposed of after an emergency; and submit any necessary reports.<br /> <br /> 7. Are emergency telephone numbers and contacts current and posted?<br /> <br /> According to the EPA, “Employees should not have to go searching through a bunch of papers for the number of the local fire department when there is a chemical fire looming in the background. It should be right by the phone. This emergency information should include the name, address, office and home phone numbers of the emergency coordinator.” <br /> <br /> When Contingency Plans are reviewed, all emergency contact information should be verified by phone or in person to ensure it is up to date.<br /> <br /> 8. What is the waste minimization plans?<br /> <br /> Large quantity generators certify with each hazardous waste manifest that the facility has a program in place to minimize hazardous waste volumes and that they are treating, storing and disposing of wastes responsibly.<br /> <br /> Small quantity generators must certify that they are making good faith efforts to reduce waste volumes and using the best waste management practices available to them (40 CFR 262.27). <br /> <br /> Compacting wastes, exploring waste exchange programs and encouraging sustainable practices are ways to verify compliance with these certification requirements.<br /> <br /> 9. Have response arrangements been made with local authorities?<br /> <br /> Local police, fire and hazmat teams are very valuable resources for facilities. Establishing a working relationship with them before an emergency helps the facility and the community responders work together and coordinate response efforts. Local response teams may also be able to provide specialized tools and equipment that are often needed during an emergency. Emergency responders and police need to be familiar with the chemicals stored at the facility and the facility’s layout so that they will be better able to assist on site responders and help keep the community safe (40 CFR 264.37). Hosting drills or exercises that involve local responders can help facilitate this requirement, and can also help onsite responders hone their skills.<br /> <br /> Sharing information on the chemicals used and stored with local hospitals will help them to be better prepared to assist after an emergency because they can familiarize themselves with hazards and develop procedures to help ensure the best treatment.<br /> <br /> 10. When were the waste management and contingency plans last updated and submitted to authorities?<br /> <br /> Contingency Plans are living documents that must be updated when chemicals, processes, facility layout or personnel named in the plan changes. The plan must be amended if it fails in an emergency, or when the list of emergency response equipment changes. Copies of the plan must be maintained onsite, and be sent to local fire, police and emergency responders, local hospitals, and state environmental and response agencies.<br /> <br /> Reviewing Contingency Plans, providing training and making efforts to minimize waste volumes help hazardous waste generators have the knowledge and ability to handle wastes safely and responsibly.

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