SOP 1.2: RCRA Hazardous Waste

Contents

1. Introduction 1

2. Regulatory and contractual requirements 1

3. Federal and State HW requirements 1

4. Evaluating HW 2

5. Determining generator size 2

6. Generator HW identification number 3

7. Processing, storing and transporting HW 3

8. Emergency planning and training 4

Attachment A - Characterisic and listed wastes 6

1. Introduction

Household hazardous waste (HHW) is the unused or leftover contents of consumer products containing hazardous ingredients. Once this waste is accepted, this Program becomes the generator and is responsible for its proper management, storage, and disposal. The Resource Conservation and Recovery Act (RCRA) found in the Code of Federal Regulations (CFR), Chapter 40-CFR governs hazardous waste (HW) while at this Facility. HW compliance regulations are to prevent mismanagement and releases of chemicals that could threaten human health or the environment, and to reduce or eliminate HW generation.

2. Regulatory and contractual requirements

HW requirements are established in the Program and State agency contract and Minn. Rules Chapter 7001, 7045.0310, 7045.0320, Minn. Stat 115A.96, 116.06 Subd. 1 (b), TSCA, FIFRA, and RCRA Subtitle C and D. For DOT information, see SOP 1.3 DOT.

3. Federal and State HW requirements

3.1 The designated Program staff responsible for ensuring RCRA and State HW compliance is the Facility Manager. This person shall ensure compliance with HW regulatory standards, rules, and policies as they relate to staff actions and conduct.

3.2 RCRA is federal legislation established in 1980 for the purpose of regulating the proper handling, storage, and disposal of HW. Every generator is required by law to determine if and how much HW they generate. The seven metropolitan counties have federal RCRA approval to perform HW inspections and issue HW licenses. All other counties in Minnesota are regulated by the Minnesota Pollution Control Agency (MPCA).

3.3 The HHW Program is a subset of the Minnesota Solid Waste Management Program.

3.4 The MPCA provides direction and approval to operate all Minnesota HHW Programs through the HHW Program and State Agency Contract. This Facility shall follow proper design, operating, storage, and disposal standards as required. The State provides indemnification to HHW Programs for waste shipped through a HW state disposal contractor.

3.5 The State also regulates and provides HHW Program licensure for acceptance and consolidation of Very Small Quantity Generator (VSQG) business HW; see SOP 3.8 OTG and VSQG Generators Licensing.

4. Evaluating hazardous waste

4.1 A chemical that exhibits one or more hazardous characteristics is a hazardous waste. These materials often include warning information and key words on the container label which alert the public that the contents may be hazardous. These key words may include:

·  DANGER – a highly toxic material, flammable, or corrosive

·  POISON – highly toxic

·  WARNING – moderately toxic

·  CAUTION – less toxic

·  NON-TOXIC – a safer product, although has no federal regulatory definition

4.2 A waste is considered hazardous if it appears on one of four HW lists, contains more than 50 ppm PCBs, or exhibits a hazardous characteristic. The hazard is determined by measuring the specific properties of the substance. A RCRA hazardous waste exhibits at least one of four characteristics (ignitability, corrosively, reactivity, or toxicity) or appears on one of four HW lists (F,P,K,U). See Attachment A of this SOP.

5. Determining generator size

If this Program is licensed to accept business HW, staff shall evaluate and determine generator size. Business HW generator status is based on the amount of HW generated in a calendar month. There are four size categories of business HW generators. This Facility is subject to LQG level of regulation, and if licensed, can accept VSQG, OTG, or MQG business hazardous waste.

·  LQG – Large quantity generators: > 2,200 pounds of HW are generated per month.

·  SQG – Small quantity generators: >220 - <2,200 pounds of HW are generated per month.

·  VSQG – Very small quantity generators: <220 pounds of HW are generated per month.

·  MQG – Minimal quantity generators: <100 pounds of HW are generated per year.

·  OTG – One time generators: <2,200 from a one-time cleanout event, which is not HW generated in normal business processes.

6. Generator HW Identification Number

·  HHW Programs are issued an HW Identification Number by MPCA (formally called EPA ID Number).

·  Once licensed, the business will be required to provide HW generation information for annual license renewals and fees.

·  A Program licensed to accept VSQG HW may assist the business in obtaining an HW ID Number (issued by the State).

7. Processing, storing, and transporting hazardous waste

The State requires all HW generators to properly manage their wastes, which includes:

7.1 Storing wastes correctly

When storing indoors:

·  Follow all fire and building codes (container grounding).

·  Keep containers closed except when adding or removing wastes. Ensure all containers are closed at the end of the business day.

·  Secure all bungs, lid rings, or lever-locks.

·  Place containers holding liquids on a surface impermeable to that particular waste.

·  Provide enough aisle space for easy access and visible inspections.

·  Containers shall be inspected at least weekly to ensure they are not leaking.

·  Separate incompatible wastes with at least a 10-foot distance, or by using a dike, berm, or wall.

·  Store wastes in an area without floor drains.

·  Keep waste containers away from equipment routes to prevent incidents.

·  Ensure HW storage time limits are not exceeded.

·  Secure and restrict access to staff responsible for managing the wastes.

When storing outdoors:

·  Follow all requirements for indoor storage as listed above.

·  Protect wastes from the elements (e.g., temperature extremes, rain, snow, direct sunlight).

·  Minimize risk of inadvertent damage to storage containers; see SOP 4.11 Waste Storage.

7.2 Marking and using proper containers

·  Correctly mark and label each container.

·  Use DOT approved containers; see SOP 4.4 Waste Packaging.

7.3 Manifesting HW shipments

A manifest is a multiple-page document that shall accompany each shipment of HW (VSQGs using a licensed HHW Program to dispose of HW may use shipping papers). The manifest is the tracking document used to show wastes have reached their proper destination. While the state-contracted HW disposal company shall prepare manifests, this Program is ultimately responsible for the accuracy of each manifest; see SOP 3.6 Manifest Tracking and LDRs.

7.4 Transporting HW

Program HW shall be transported by the state-contracted HW disposal company. Generators are forever responsible for their HW. When waste is turned over to the state-contracted HW disposal company, this Program may still be liable for cleanup costs if a release occurs. If this Program chooses to use a transporter other than the state-contracted HW disposal company, indemnification will no longer apply. This Program shall transport and dispose of HW correctly, following DOT requirements; see SOP 1.3 DOT.

7.5 Licensed VSQG consolidation sites

VSQG business-generated HW may be disposed of at licensed VSQG consolidation sites. Household and business HW may be commingled and shipped through the state-contracted HW disposal company. Although each business may pay disposal fees, a licensed VSQG consolidation program is a convenient and low-cost disposal option: see SOP 3.8 OTG and VSQG Generators - Licensing. Minn. Rules requires businesses generating HW to:

·  Apply and receive approval from the licensed VSQG consolidation site.

·  Obtain an HW ID number.

·  Transport waste using a business vehicle.

·  Follow DOT requirements while transporting the HW to the Facility.

·  Retain HW records (shipping papers) documenting proper HW disposal.

8. Emergency planning and training

8.1 Emergency planning

All HW generators are required to prepare for an emergency. This shall include:

·  An on-site telephone or communication system, for use in an emergency.

·  Fire-control equipment suitable for the materials used or stored.

·  Spill kit, stocked and maintained.

·  Decontamination equipment (e.g., emergency shower, eye wash), routinely tested and maintained.

·  HW storage areas, free of drains to prevent environmental releases.

·  Prior arrangements with local authorities/responders in the event of an emergency.

·  Updated Emergency Contingency Plan; see SOP 2.10 HW Contingency Plan.

8.2 Spill response

Staff is responsible for cleaning up incidental spills that happen in the course of performing duties, and shall not attempt to control or clean up any spills requiring assistance beyond their capabilities; see SOP 2.6 Spill Response.

8.3 Training staff

Facility staff is subject to HW training requirements. OSHA also requires staff to be adequately trained; see SOP 1.1 OSHA and 1.4 HHW Training requirements. This Program is required to train staff according to their job responsibilities, including:

·  To ensure all required training is successfully obtained (e.g., HW, DOT, Health and Safety); see SOP 1.4 HHW Training Requirements.

·  HW container management (container marking and labeling, storage requirements, weekly inspections, preparing for shipment, and manifesting).

·  Using fire-suppression equipment.

·  Cleaning up small or incidental spills; see SOP 2.6: Spill Response.

·  Emergency response procedures; see SOP 2.10 HW Contingency Plan.

·  Safe waste-handling procedures.

·  Instruction to retain documented training (names of staff, training dates, class agenda/content, and certificate of completion). Keep required training documentation and HW shipment records for a minimum of three years (preferably indefinitely); see SOP 3.4: Participant Training (Greater Minnesota) and Annual Reporting.

8.4 Health affects

This Program shall establish a staff medical monitoring policy: see SOP 2.13: Medical Monitoring Program. There are two types of health dangers when chemical exposures occur:

·  Chronic – gradual and cumulative, occurs through repeated chemical exposures over an extended period of time (e.g., liver or kidney damage, allergic reactions, nervous system disorders).

·  Acute – immediate, characterized by severe symptoms with a sudden onset (e.g., skin burns from acid or fire, eye damage from a splashing chemical, disorientation or unconsciousness from carbon monoxide exposure).


Attachment A

If not excluded, a waste is considered hazardous if it is either “characteristic” or “listed.”

Characteristic – chemical type based on waste properties; for a complete list: see Minn. Rule 7045.0131, general waste codes, and CFR references which include:

Corrosive D002 40CFR 261.22

Ignitable D001 40CFR 261.21

Lethal MN01 40CFR 261.24

Oxidizers D001 40CFR 261.21

Reactive D003 40CFR 261.23

Toxic D001, D004-D043 40CFR 261.24

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Corrosive wastes:

·  any liquid able to corrode 1/4 inch of steel per year (battery acid)

·  pH <2

·  pH > 12.5

·  able to burn or destroy living tissues

Ignitable wastes:

·  flash point of <140 degrees F

·  spontaneously combustible

·  includes ignitable, compressed gas

·  defined as an oxidizer (DOT rules)

Lethal: can cause severe health effects or death when ingested, inhaled, or absorbed through the skin (arsenic, poisons)

Oxidizing wastes:

·  wastes that add oxygen to a fire

·  often have “per” at the beginning of the name, “oxide” at the end of the name, or “ate” in its chemical name

Reactive wastes:

·  unstable or explosive wastes (lithium batteries)

·  react violently with water (lithium, sodium)

·  form toxic or explosive gasses (cyanide, sulfide)

Toxic or pesticide wastes:

·  capable of causing injury or death through ingestion, inhalation, or absorption

·  capable of causing cancer (carcinogens), genetic damage (mutagens), and fetal harm (teratogens)

·  under acidic conditions, releases toxic metals, pesticides, or volatile organic chemicals (photographic fixers, chemical wastes)

·  pesticide wastes are classified as “Universal Waste”

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Listed – wastes generated from specific industry processes. Use MSDS sheets to identify the chemical components in the product, then see if it appears on one of four lists: F, P, K, or U (see Minn. Rule 7045.0135), general waste codes, and CFR references, which include:

Non-specific sources F-List 40CFR 261.31

Acute P-List 40CFR 261.33(e)

Specific sources K-List 40CFR 261.32

Toxic U-List 40CFR 261.33 (f)

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1.2 RCRA Hazardous Waste Effective date 9/26/2008 4

F-listed wastes:

·  degreasing solvents

·  paint/lacquer thinners

·  brake/carburetor cleaners

·  dry clean solvents

·  distillation

·  others

P-listed wastes:

·  Acutely hazardous

·  Fatal to humans in low doses (arsenic, strychnine, cyanides)

·  others


K-listed wastes:

·  wood preserving

·  pesticide manufacturing

·  iron and steel industries

·  others

U-listed wastes:

·  Toxic and others

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