Managing Hazardous Material at research farm locations

Transcription

1 Managing Hazardous Material at research farm locations Types of waste Hazardous waste Universal waste Used oil ewaste TSCA Applicable rules Hazardous Waste FAC Used oil FAC Universal waste lamps FAC Transportation 49CFR 1

2 Hazardous Waste Management in UF Research Laboratories Overview The Resource Conservation & Recovery Act (RCRA) of 1976 established Cradle to Grave management responsibility for generators of Hazardous Waste Federal/State regulations define standards for Hazardous Waste Management University of Florida Hazardous Waste Management policies and procedures are based on Federal and State regulations Have waste? No happy day Yes management plan HW Management plan Step 1 Assign Waste Manager(s) Step 2 Facility audit How much HW do we generate in a month? What kind of waste do we generate? Step 3 Evaluate generator requirements Implement requirements Step 4 regular reviews Step 5 regular disposal Step 6 keep records of every transfer 2

3 Step 1 Audit waste streams Waste Definitions What is hazardous waste? Hazardous waste 40 CFR 261 Two types Listed Characteristic 3

4 Listed hazardous waste U list toxic carbon tetrachloride U211 xylene U239 P list acutely toxic sodium azide P105 dinoseb P020 parathion P089 Characteristic Hazardous Waste Flammable fp < 60 C Corrosive ph< 2 or > 12.5 Reactive DWW, forms toxic gas, fumes Toxic contaminants at ppm level Metals: Pb, Hg, Cd, Ag, Ar, Ba, Chemicals carbon tet, 2,4 D, IGNITABLE Flash Point < 140 F Fuels gasoline Solvents paints, thinners Propellants aerosol cans 4

5 CORROSIVE Any liquid waste with a ph < 2 or > 12 Acids (Muriatic acid, Sulfuric acid) Bases (Degreasing Cleaners) Floorwax Strippers Etching solutions (Strong Acid) LISTED HAZARDOUS WASTE Examples; acetone, xylene, methylene chloride, 1,1,1 trichloroethane Read container label, is constituent on list? If yes, hazardous when disposed Not sure? Contact EH&S Typical waste streams Hazardous waste Fuel Pesticides Herbicides Solvents from cleaning or painting Degreasing Aerosols, cans Spill clean up rags 5

6 Step 2 Implement compliance program HW Generator classes Conditionally exempt Small Quantity Generator Generate < 100 kg mo HW and < 1 qt P listed waste Accumulate < 1000 kg at any one time Insure waste properly disposed Keep disposal records training HW Generator Classes Small Quantity Generator Gen > 100 and < 1000 kg mo. < 1 qt P listed waste Accumulate no more than 6000 kg Accumulate waste no more than 180 days 6

7 SQG Requirements Obtain EPA ID number Use HW manifest system Emergency Planning One employee designated as Emergency Coordinator on 24 hr call Next to telephone, post: EC name and phone number Fire department phone number Location of fext,spill control equipment, and fire alarm. SQG requirements Train personnel regarding proper HW handling and emergencies Keep records 3 years Meet pre transport requirements for packing labeling, marking, and placarding Meet satellite accumulation rules Maintain and operate the facility in a clean safe manner SQG requirements Emergency equipment required Telephone or two way radio Internal communication or alarm system Fire and spill control system Neutralizing equipment, spill absorbents, overpack drums, standby 55 gallon drums.. Test and maintain the emergency equipment Maintain isle space for evacuation, inspecting drums, etc (no less than 3 feet) 7

8 SQG requirements Attempt to make arrangements with local fire and police, hospitals, and emergency response contractors with regards to emergency arrangements, hazards of materials handled, layout of facility, etc Containers must be kept closed and in good condition, inspected at least weekly, be compatible with the waste stored, kept away from incompatible wastes. Records of these inspections must be kept. SQG requirements LDR form must accompany manifests Large Quantity Generator!!! 8

9 Examples of Chemical Wastes Used or spent chemicals (liquid, solid, or gas) Chemicals that you no longer have any use for Out of date or expired chemicals Spilled chemicals Chemicals abandoned by previous lab users Materials contaminated with chemical waste Lab waste Unused or spent chemicals Solvents Reagents Acids, bases Solutions Wipes Lab ware Shop waste Parts washers solvents, metals Sand blasters metals Used oil no flammable s Batteries no alkalines, get receipt Spray cans empty? Rags flammable? Old gas not in oil Filters oil vs. fuel 9

10 PARTS WASHING WASTE Typically contaminated with heavy metals and degreasing solvent Three separate waste streams: fluid, filter and sludge (if unit distills) Should be considered hazardous waste unless testing confirms otherwise DO NOT MIX PARTS WASHING WASTES WITH USED OIL Sand blasting AC COIL CLEANING Cleaning is typically a strong base ( a characteristic waste) Test post use to determine ph Only discharge to sanitary sewer 10

11 ANTIFREEZE Can Be Hazardous Due To Contact With Heavy Metals Or Organics Keep Container Closed Records Must Be Retained For Five Years ANTIFREEZE ANTIFREEZE AEROSOL CANS Extremely flammable solvents and propellants Only Completely Empty cans are allowed in trash Otherwise collect in container for disposal with EHS Remove spray tip Label as Hazardous Waste FERTILIZERS Are oxidizers Use per label or Dispose of as hazardous waste. Do not accumulate old fertilizers 11

12 PESTICIDE SPRAY RESIDUES Many pesticides and herbicides are hazardous waste when disposed Pesticide rinsates Rinse Water Improperly disposed RINSE WATER from application equipment has great potential for causing ground and surface water contamination. Don't discharge rinse water to the ground. Don't discharge rinse water to septic systems you're increasing the chance that it will get into the ground water. Don't discharge rinse water to ditches or streams that's illegal and may cause damage to neighbor's crops, trees, or be a serious hazard to fish and other wildlife. Don't bury rinse water it may contaminate ground water. Do minimize rinse water wash out equipment only when necessary. Do re apply rinse water to a labeled site this is allowed under federal law and will not result in an applied concentration above the label recommendation. Do re use rinse water to dilute the next batch of formulation, as long as the site to which the rinse water is applied is a labeled site. Up to five percent of the water for dilution may be rinse water (Figure 16). Pesticide rinsates Rinse Water Improperly disposed RINSE WATER from application equipment has great potential for causing ground and surface water contamination. Don't discharge rinse water to the ground. Don't discharge rinse water to septic systems you're increasing the chance that it will get into the ground water. Don't discharge rinse water to ditches or streams that's illegal and may cause damage to neighbor's crops, trees, or be a serious hazard to fish and other wildlife. Don't bury rinse water it may contaminate ground water. Do minimize rinse water wash out equipment only when necessary. Do re apply rinse water to a labeled site this is allowed under federal law and will not result in an applied concentration above the label recommendation. Do re use rinse water to dilute the next batch of formulation, as long as the site to which the rinse water is applied is a labeled site. Up to five percent of the water for dilution may be rinse water (Figure 16). 12

13 Fuel Bad or contaminated fuel Spilled fuel Fuel filters Step 3. Accumulation of waste Area in lab or shop for waste Have vendor collect Area in lab or shop for waste Move to central collection area Accumulation Container Labeled Good condition Closed except when adding.. Compatible Segregated from product Prevent spills 13

14 Pic of accumulation here 14

15 Universal waste Flourescent lamps Batteries Mercury devices Universal Waste Fluorescent Lamps Batteries Hg containing devices Some pharmaceuticals 15

16 Mercury Containing Lamps Universal Waste Fluorescent Lamps (4/8 ft, Circular, U bent) Compact Fluorescent Lamps High Intensity Discharge (HID) Mercury Vapor High Pressure Sodium Accumulation lamps/bulbs Labeled universal waste lamps Boxed Max accumulation time = 1 year Universal Waste All containers must be labeled Specific labels All containers/devices must be dated with accumulation start date 16

17 BATTERIES Universal Waste ALKALINE BATTERIES CAN BE PLACED IN TRASH CAR BATTERIES HMM BATTERIES CONTAINING MERCURY, LEAD, SILVER, CADMIUM, OTHER HEAVY METALS Bring to HMM 17

18 Universal Waste Key points Specific labels Labels must be dated Containers for lamps, hg devices 1 year accumulation limit Used oil Petroleum oil Synthetic oil Hydraulic fluid Not food oils 18

19 Used oil wastes Used oil Filters Spill clean up rags Used Oil / Waste USED OIL waste includes: vacuum pump oil, synthetic oil, motor oil, transmission and other petroleum based oils and greases. Not food oil. Label collection containers specifically with the words USED OIL clearly displayed. OILY WASTES absorbents (Towels, Kitty Litter, etc.) used to collect spilled oil must be collected for proper disposal through EH&S USED OIL containers must be in secondary containment =/> 110% of the volume of the largest container stored EH&S provides USED OIL labels Containment must be free of spills and debris Accumulation used oil Labeled used oil Closed containers Good condition Spill containment = 110% of largest container Clean up spills Consider double wall tank No solvents or fuel 19

20 Pic of used oil here 20

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22 Other? Old tires freon Stormwater Demolition waste ewaste Pcb s, ballasts 22

23 ewaste Pb in glass, solder Not regulated if properly recycled Vendors contact EHS Stormwater ABSOLUTELY NO DISCHARGE OF WASTES OR OTHER MATERIAL TO STORM DRAINS OR TO THE ENVIRONMENT. Campus Storm Drain Lake Alice Storm water = Rain water ONLY Storm drains Prohibited discharges include: mop water Washing machine discharge chemicals paints vehicle or equipment washing building washing Contained water Water from equipment/systems Nothing but Stormwater! 23

24 Discharges to stormwater Alternatives Sanitary sewer via oil water separator Grassy area = no contamination/ocassional use Spills What to report? * When to report? ** Where to report? Emergency Coordinator State Warning Point EHS What to report Petroleum Based Spills Spills into or involving state waterways (any amount) Spills greater than 25 gallons (or potential > 25 gallons) Spills requiring any state/federal notifications or assistance Chemical Spills All SARA/EHS/CERCLA Releases All spills threatening population or the environment All spills requiring evacuation When in doubt... call the State Warning Point at

25 The Bureau of Emergency Response (BER) Contractor List DEP 24 Hour Emergency Response # (800) Florida Dept. of Environmental Protection, Bureau of Emergency Response Emergency Response Contractors Emergency Response Contractors are listed by the county in which they maintain an office. Most Emergency Response Contractors can provide service to other counties and some provide service statewide. BER does not endorse any contractor and a firm s absence or presence does not imply prejudice or impropriety. Call the FDEP Bureau of Emergency Response at (850) with any questions. 24 Hour Emergency Response Contractors [PDF 53KB] Approved Discharge Cleanup Organizations [PDF 18.57KB] Reporting Requirements APPENDIX 4. Spill Reporting Requirements Public Law and Public Law (CERCLA) require immediate notification of the appropriate agency of the United States Government of a discharge of oil or hazardous substances. Any such person who fails to notify immediately such agency of such discharge shall, upon conviction, be fined not more than $10,000 or imprisoned for not more than one year, or both. Pursuant to Chapters 376 and 403, Florida Statutes: Any owner or operator of a facility who has knowledge of any release of a hazardous substance from a facility in a quantity equal to or exceeding the reportable quantity (see MSDS sheet) in a 24 hour period shall immediately notify the State Warning Point (see Appendix 2). The owner or operator having a discharge of petroleum products exceeding 25 gallons on a pervious surface (or any amount in a water body) must report such discharge to the Department of Environmental Protection or the State Warning Point (see Appendices 2 and 3). The penalty is not in reporting a spill, it is in failing to report a spill. REPORT THE FOLLOWING INFORMATION 1. Name, address, and telephone number of person reporting 2. Name, address, and telephone number of person responsible for the discharge or release, if known 3. Date and time of the discharge or release 4. Type or name of substance discharged or released 5. Estimated amount of the discharge or release 6. Location or address of discharge or release 7. Source and cause of the discharge or release 8. Size and characteristics of area affected by the discharge or release 9. Containment and cleanup actions taken to date 10. Other persons or agencies contacted SPCC Spill Prevention and Countermeasures Required? Deadline extended. 25

26 Waste disposal DOT training Vendor EHS IH, HMM DOT training March 29, 2011 M E M O R A N D U M TO: IFAS Center Directors FROM: Philip S. Collis, Ph.D. Associate Director Environmental Health and Safety SUBJECT: DOT Training If your center ships hazardous chemical waste for disposal, you are required to have a DOT trained staff person to sign the manifest. Most centers do not have a trained individual. UF has made arrangements with National Environmental Trainers, Inc. to provide an online training for $95/person. If you need to train a representative, please send me the individual s name and the chartfield information for the $95 payment by April 15, I will register the person and send back the login information required. The individual will then have a 30 day window to complete the training. If you already have a trained representative or do not generate hazardous chemical waste, please send me that information by the 15 th also. Thank you for your cooperation and please call me if you have questions or require additional information. Megan A. Thomas Megan A. Thomas Senior Secretary Environmental Health & Safety (352) mthomas@ehs.ufl.edu RCRA TRAINING 49cfr262.34c(iii) the generator must insure that all employees are thoroughly familiar with proper waste handling procedures, relevant to their responsibilities during normal facility operations and emergencies 26

27 RCRA training Select disposal vendor UF does due diligence Get contract price Recommend using UF vendor Number one rule FIRST IMPRESSIONS ARE EVERYTHING 27

28 Assistance Assigned Industrial Hygienist Melissa Crowder, Vince McLeod, Tom Ladun to find out who Bill Coughlin

29 references pdf htm References cont. hw/hazardous/business/agpesticides03.pdf