Workshop B Practical Tips & Trends in RCRA Hazardous Waste - PDF document

Workshop B Practical Tips & Trends in RCRA Hazardous Waste Management and Enforcement Tuesday, March 24, 2020 9:45 a.m. to 11 a.m .

Biographical Information Tim W. McDaniel, CIH, CSP, EHS Manager Navistar, Inc., 6125 Urbana Rd., Springfield, OH 45502 937-390-4024 Tim.mcdaniel@navistar.com Tim started his career with the Regional Air Pollution Control Agency in Dayton, Ohio in 1985 as an inspector and permit writer. In 1987 he went to work at Navistar for QSource Engineering then joined Navistar in 1989. During his tenure at Navistar, the company has received numerous awards from US EPA and Ohio EPA for pollution prevention and environmental excellence as well as awards in safety and ergonomics. The Springfield Assembly Plant has been registered to ISO 14001 since 2003. Tim’s current responsibilities include ISO 14001, regulatory participation in Ohio and environmental management at the Springfield Assembly Plant. Tim currently serves on the Clark County Solid Waste Management District Policy Committee and the Clark County LEPC. He is past chairman of the Truck Manufacturers Association Environment Committee and the Ohio Manufacturers Association Environment Committee and served on the Great Lakes Regional Pollution Prevention Roundtable. Tim is a graduate of Eastern Kentucky University with a B.S. In Environmental Resources/Biology and he received both an MS and MA from Indiana University in Environmental Science and Ecology. Christa Oerly Russell, Manager of Consulting Services Trinity Consultants, 8910 Purdue Road, Suite 670, Indianapolis, Indiana 46268 317-695-4644 crussell@trinityconsultants.com Christa has more than 41 years of experience in environmental compliance, multi-media regulatory permitting, solid and hazardous waste management, and in industrial coatings and cement manufacturing. Christa began her environmental career in 1979 with Missouri DNR in air permitting and expanded her regulatory experience with IDEM working predominantly in solid and hazardous waste permitting and compliance. Christa’s regulatory experience was followed in 1991 by a position as corporate Manager of Environmental Affairs for an industrial coatings manufacturer and included multimedia compliance responsibilities for 26 manufacturing facilities in the U.S. and Canada. In 1998 Christa joined Lone Star Cement Company as corporate Director of Environmental Compliance with compliance responsibilities for multiple cement plants and terminals. During her time in industry, Christa was also active in numerous industry work groups, including participation on several cement industry and coatings industry association committees. Christa served for several years as a Director on the Board of the Indiana Air and Waste Management Association as Programs Committee Chair. Christa joined Schreiber Yonley & Associates (SYA) in 2004 as a Senior Engineer working primarily with air permitting and emissions control technology evaluations for the cement industry and performing multimedia audits and providing assistance with RCRA compliance. SYA became part of Trinity Consultants in 2014. In 2018, Christa became the manager of Trinity’s Indianapolis, Indiana office. Christa has a Bachelor of Science degree in Chemical Engineering from the University of Missouri.

What to Expect During a Resource Conservation and Recovery Act (RCRA) Compliance Audit ymposium  March 24, 2020 2020 S ustainability & Environmental Health and S afety S Christa Oerly Russell Manager of Consulting S ervices 317-695-4644 crussell@ trinityconsultants.com

Topics to be Discussed ˃ Introduction to Hazardous Waste (HW)  Overview of Generator Categories ˃ Generator Improvements Rule ˃ Common RCRA Generator Violations to Avoid 2

Overview of HW Generator Categories

Requirements by Category (1/2) Generator ID all HW Manifest Pre‐ Preparedness & Land Disposal Category Streams Transport Prevention Restrictions  VSQG *      SQG      LQG * Alt hough not subj ect t o HW manifest requirement s of 40 CFR 262 S ubpart B, VS QGs must ensure t hat hazardous wast e is delivered t o a person or facilit y who is aut horized t o manage it .

Requirements by Category (2/2) Generator Manage HW in RCRA Section Emergency Contingency Biennial HW Category Approved Tanks, 3010 Response Plan Report Containers, etc. Notification Coordinator Available VSQG  *   SQG  **    LQG * S QGs must manage HW in accordance wit h §262.16, which references t he int erim st andards in 40 CFR 265.17(b) for ignit able, react ive, and incompat ible wast es. ** LQGs must manage HW in accordance wit h §262.17, which references t he int erim st andards in 40 CFR 265 for process vent s, equipment leaks, t anks, surface impoundment s, cont ainers, et c.

Requirements by Category (1/2) Generator ID all HW Manifest Pre‐ Preparedness& Land Disposal Category Streams Transport Prevention Restrictions  VSQG *      SQG      LQG * Alt hough not subj ect t o HW manifest requirement s of 40 CFR 262 S ubpart B, VS QGs must ensure t hat hazardous wast e is delivered t o a person or facilit y who is aut horized t o manage it .

Requirements by Category (2/2) Generator Manage HW in RCRA Section Emergency Contingency Biennial HW Category Approved Tanks, 3010 Response Plan Report Containers, etc. Notification Coordinator Available VSQG  *   SQG  **    LQG * S QGs must manage HW in accordance wit h §262.16, which references t he int erim st andards in 40 CFR 265.17(b) for ignit able, react ive, and incompat ible wast es. ** LQGs must manage HW in accordance wit h §262.17, which references t he int erim st andards in 40 CFR 265 for process vent s, equipment leaks, t anks, surface impoundment s, cont ainers, et c.

Hazardous Waste Generator Improvements Rule

HazWaste Generator Improvements Rule ˃ Final Federal Rule: November 28, 2016  81 FR 85732 ˃ Affected regulations  40 CFR 257– 258, 260– 268, 270-271, 273, 279  >60 changes to the regulations, plus about 30 technical corrections ˃ Affected entities:  All hazardous waste generators (CES QG, S QG, LQG), TS DFs, Transporters  All industry sectors, facility types, locations ˃ The Rule has been adopted and is effective in IN and KY

Major Provisions of the Rule ˃ Reorganization ˃ Episodic Generation ˃ Consolidation of CES QG (VS QG) Waste at LQGs ˃ Ignitable and Reactive Waste Waiver ˃ Waste Determination Expectations ˃ Emergency Preparedness and Prevention ˃ Labeling ˃ S atellite Accumulation Provisions ˃ Closure Requirements ˃ Additional Changes and Clarifications

Reorganized Rule Structure Provision Original Citation in 40 CFR New Generator Citation in 40 CFR Definition of Generator §260.10, 261.5, & 262.34 §260.10 Categories Hazardous Waste §262.11 and 262.40(c) §262.11 Determination and Recordkeeping Generator Category §261.5(c)‐(e) §262.13 Determination VSQG Provisions §261.5(a), (b), (f)‐(j), and 258.28 §262.14 Satellite Accumulation Area §262.34(c), 265.171, 265.172, and §262.15 Provisions 265.173(a) SQG Provisions §262.34(d)‐(f) and 268 §262.16 LQG Provisions §262.34(a), (b), (g)‐(i), (m), and 268 §262.17 USEPA Identification Numbers §262.12 §262.18 Landfill Ban for Liquids §258.28 §262.35

Various “Minor” Changes ˃ “ VS QG” (Very S mall Quantity Generator) replaces “ CES QG” ˃ “ Central Accumulation Area” defined  S torage vs. central accumulation  Central vs. satellite accumulation

Waste Determinations ˃ Must accurately document hazardous waste determinations (§262.11(f))  Applies to S QGs and LQGs  Applies at point of generation – before diluted, treated, mixed, or otherwise altered  Does not apply to exempted wastes (although separate recordkeeping may be required)  Does not specifically apply to non-hazardous wastes (although recommended as a best management practice) ˃ Using knowledge to determine waste characteristics  Moves from 262.11(c)(2) to 262.11(d)(2)  Lists types of knowledge previously accepted by US EP A  S pecifically allows alternative tests as part of knowledge

Marking/Labeling Requirements ˃ Applies to all S QGs, LQGs, Transporters ˃ Label must indicate  The words “ Hazardous Waste”  Identification of hazards NEW ♦ Choice of established methods: DOT , OS HA, NFP A, …  Add all waste codes (prior to shipment) NEW ♦ May use recognized electronic option – e.g., bar codes ♦ Exception for lab packs  Accumulation start date ˃ For vessels that can’ t be labeled (e.g., some tanks, drip pads, containment buildings)  Info can be in records or logs kept at or near the location of the vessel