Document KROErzOr4j2EGJXp5yR46x9kK

RCRA TRAINING 00 A 055787 CO NFIDENTIAL AGENDA Opening Remarks............Jill McCullough Introduction To RCRA RCRA Definitions............ Jill McCullough Classifying Wastes Training Requirements...Glyn Boudreaux Permit Requirements Temporary HW Storage Land Ban......................... Liz Simpson Groundwater....................Glyn Boudreaux Questions And Answers DO A 055788 CONFIDFNTTAL R esource C onservation R ecovery A ct DO A 0 5 5 7 9 0 CO NFIDFNTIAL RCRA WHAT IS IT? A law developed in 1976 to regulate the management of hazardous and solid waste. It applies to generator's, transporters, and treatment, storage, disposal, and recycle units. DO A 0 5 5 7 9 1 OONFTDFNTTAL LIABILITIES NON-COMPLIANCE Civil Penalty $25,000/Day/Occurence Criminal Penalty $50,000 and/or 2 Years Imprisonment Knowing Violation $250,000 and/or 15 Years Imprisonment Shut Down Facility DO A 0 5 5 7 9 ? C O N F T D F N T IA L ACTUAL CASES Marine Shale Fined $1.7MM For 50 Violations Albert Turnin- 2 Years Imprisonment For 'Knowing Endangerment Joseph O'Toole- 23 Months Imprison ment and $184,000 Fine k:ra definitions Solid Waste Hazardous Waste Container Tank Generator Empty Container Mixture Rule Spill Residue WASTE CHARACTERIZATION 1. IS THE MATERIAL A W\STE? Abandoned Through Treatment Storage Disposal Recycle WASTE CEIARACTERIZATION 2. Is It An Exempted Solid Waste? Sanitary Sewage Permitted Water Discharge DO A 0 5 5 7 9 6 CO NFIDENTIAL W^STE CHARACTERIZATION 3. If It Is A Solid Waste, Is It An Exempt Hazardous Waste? Household Waste Waste Farm Crops WASTE CHARACTERIZATION 4. Is The Solid Vsbste Generated From A Non-Specific Source Such As A Spent Solvent? F`If--I - Listed Methylene Chloride Methanol Toluene DO A 0 5 5 7 9 8 C O N F ID F N T T A l WASTE CHARACTERIZATION 5. Is The Solid Waste Generated From A Specific Process? KI| / I - Listed Heavy Ends From The Production of Ethylene Dichloride DO A 0 5 5 7 9 9 OONFTDENTTAl \aASTE characterization 6. Is The Solid Waste A Discarded Commercial Chemical? 'P' or 'll' - Listed Carbon Disulfide Bromomethane WASTE CHARACTERIZATION 7. Does the Waste Exhibit Any Hazardous Waste Characteristics? "D* Listed Ignitable - Flash point 140F or less Corrosive - pH2 or less or 12.5 or more Reactive - Explosions or violent reactions Toxicity - Leachate Exceeds Listed Concentration IT! Z C U. C < i--' - CONFTDFNTTAL TOXIC CHARACTERISTIC Expands EP Toxic List From 14 to 39 Chemicals Effective on September 25, 1990 Utilizes T.C.L.P. Method More Waste Streams Will Become Hazardous Modify Hazardous Waste Permit to Incinerate These Waste Codes 1VI1N3QIJNOD 08990 y oa ATTACHMENT 5 TABLE 1 MAXIMUM CONCENTRATION FOR THE TOXICITY CHABA>.*kISTIC EPA HW Contaminant R#9ulitory L<vl (mg/1) 0004 0005 0018 D006 DO 19 0020 DO 21 D022 0007 D023 D024 D025 D026 DO 18 D027 D028 D029 DO 30 0012 DO 31 DO3 2 DO3 3 D034 0008 DO 13 D009 DO 14 D035 D036 D037 D038 DO 10 D011 D039 DO IS D040 DO41 D042 D017 D043 Arsenic 5.0 Bariua 100.0 Benzene 0.5 Cadmium Carbon tetrachloride 1.0 0.5 Chlordane 0.03 Chlorobenzene Chloroform Chromium 100.0 6.0 5.0 o-Cresol n-Creaol 200.0 200.0 p-Cresel 200.0 Cresol 200.0 2,4-D 10.0 1,4-Dichlorobenzene 7.5 1,2-Dichloroethane 0.5 1,1-Dichloroethylene 0.7 2,3-Dinitrotoluene 0.13 Endrin 0.02 Heptachlor (and its hydroxide) 0.008 Hexachlorobeasene 0.13 Hexachlorofautadiene 0.5 Hexachloroethaee 3.0 Lead 5.0 Lindane 0.4 Mercury 0.2 Methexyclor 10.0 Methyl ethyl ketone 200.0 Nitrobenzene 2.0 Pentechlorophenol 100.0 Pyridine 5.0 Selenium 1.0 Silver 5.0 Tetrachloroethylene 0.7 Taxaphene 0.5 Trichloroethylene 0.5 2,4,5-Trichlorophenol 400.0 2,4,6-Trichlorophenol 2.0 2,4,5-TP (Silvex) 1.0 Vinyl chloride 0.2 *Indicates addition to toxicity characteristic list. ^Hazardous Waste Nu^er LS:sb 7/90 A 055803 C O N F ID F N T T A L IaASTE characterization 8. Generator's Responsibility To Correctly Characterize waste. Process Knowledge Waste Analyses UNIFORM WASTE CHARACTERIZATION SUMMARY SHEET ALL QUESTIONS MUST BE ANSWERED BEFORE WASTE CAN BE ACCEPTED FOR DISPOSAL. MSDS OR EQUIVALENT MUST BE ATTACHED. 1. TWC CODE 2. TX WASTE STM NO 3. LA. WASTE TYPE NO ___________ 4. LA DEQ NON-HAZD CODE 5. MICH EVS NO 6. MICH ACT 64 CLASS 7. MICH ACT 136 CLASS 8 RCRA/EPA HAZARDOUS CODE _______________________ 9 PLANT CONTACT 10 PHONE NO _ ALTERNANT PHONE NO _ 11 PLANT/DIV 12 ACCOUNT NO 13 WASTE NAME __________________________________________ 14 IDENTIFICATION BY PLANT KNOWLEDGE 15. IDENTIFICATION BY COMPOSITION: (CONCENTRATION) AS PACKAGED AS GENERATED CONSTITUENT TYPICAL RANGE TYPICAL RANGE %% SAND,DIRT,DEBRIS ABSORBANT MATERIAL WATER PROCESS KNOWLEDGE ANALYSIS DO A 055804 CONFTDFNTIAL COMPLETE ITEMS 16 THROUGH 23 "AS GENERATED" PROCESS KNOWLEDGE ANALYSIS 16. CORROSIVE TO STEEL? YES NO RATE 17. WASTE STREAM pH ______ 18. FLASHPOINT 19. CONSTITUENTS OF CONCERN: A. TOTAL HALOGEN CONTENT %CL %BR %F %I____ WASTE CONTAIN MORE THAN T*OZ. OF I? Y B. NON-HALOGENATED ORGANICS: % C. HALOGENATED ORGANICS: % D. PCB'S: <50 PPM >50 PPM E. TOTAL SOLIDS % F. DISOLVED SOLIDS % G. ASH (PARTICULATES! % H. FREE CHLORINE: PRESENT ABSENT I. RADIOACTIVE: YES NO J. MERCURY: <100 PPM >100 PPM K. NITROGEN: <1% 1-10% >10! L. SODIUM: <1% T-10% >10% M. POTASSIUM: <Ti 1-lfil >101 n. btu/lb <5000 5ooo-i4Tnnr >T7M0 O. SULFUR I- P. CYANIDE % N 20. ARE ANY OF THE FOLLOWING METALS PRESENT? YES AS____ Ba____ CR____ Cd____ Pb____ Ag____ Se____ Hg NO (INDICATE CONC IN PPM 21. PHYSICAL STATE (AT 70 DEG F) DENSITY #/GAL OR #/FT3 LIQUID SOLID SLUDGE SLURRY 22. SINGLE PHASE MULTI-PHASE ABSORBED SOLIDIFIED 23. PUMPABLE AT 70 DEG F. YES NO COMPLETE ITEMS 24 THROUGH 28 "AS PACKAGED" 24. CHEMICAL REACTIVITY (DESCRIBE)________________________ 25. EXPLOSION/FIRE HAZARD (DESCRIBE) 26. PERSONNAL HANDLING/EXPOSURE PRECAUTIONS (DESCRIBE) 27. MATERIALS OF CONSTRUCTION INCOMPATIBILITY (DESCRIBE) 28. VOLUME OF WASTE MATERIAL (IN POUNDS)INVENTORY ANNUAL RATE: ONE-TIME WASTES EXPECTED SHIPPING FREQUENCY HOW CONTAINED/PACKAGED THIS SHIPMENT WILL _____ OR WILL NOT _____ NEED NOTIFICATION UNDER LANDBAN, SPENT SOLVENTS, THIRD THIRD OR TC REGULATION. I CERTIFY THAT THE INFORMATION IN THIS SECTION IS TRUE ACCURATE AND COMPLETE. SOURCE PLANT SIGNATURE AND TITLE DATE SIGNED BL LM 8/28/90 DO A 055805 CONFIDENTIAL A 055806 C O N F ID F N T T A L LAND DISPOSAL BAN EPA Will Evaluate Each Listed RCRA Hazardous Waste And Establish The Conditions Under Which Continued Land Disposal Will Be Allowed. LAND DISPOSAL BAN Establish Treatment Standards Based On BDAT Best Demonstrated Available Technology f~` rS 19 00 A 055808 CONFTDFNTTAL SCHEDULE FOR SETTING TREATMENT STANDARDS Spent Solvents Dioxins November 8, 1986 California List July 8, 1987 First Third August 8, 1988 Second Third June 8, 1989 Third Third May 8, 1990 Toxic Characteristic DO A 0 5 5 8 0 9 C O N F ID F IM T IA L HARD HAMMER On August 8, 1990 Land Disposal Oi All Hazardous Wastes Which Do Not Meet Treatment Standards Will Be Be Prohibited. / LAD IMPACT Cannot Incinerate Certain Wastes F024 Wastes including but not limited to, distillation residues, heavy ends, tars, and reactor cleanout wastes from the production ot chlorinated aliphatic hydrocarbons having carbon content from 1 to 5, utilizing free radical catalyzed processes. K028 Spent catalyst trom the hydrochlorinator reactor in the production of 1,1,1-trichloroethane. K022 Distillation bottom tars from the production of phenol/ acetone from cumene. DO oo^ 0 558^ 0 I AD DO A 0 5 5 8 1 1 C O N F T D F N T T A l. LAD IMPACT Continue To Evaluate Waste Streams Contend With The State's Version DOW CHEMICAL U.S.A. July 25, 1990 LOUISIANA DIVISION P. O. BOX ISO PLAQUEMINE. LOUISIANA 70765-0150 504 389-8000 TO ALL DIVISION WASTE GENERATORS NOTIFICATION OF HAZARDOUS WASTE SHIPMENTS AND NEW HAZARDOUS WASTE CODES The Third Third regulations became effective on August 8 and shortly thereafter the new toxic characteristic regulations become law. We must have in our files a notification form signed by you or a knowledgeable, responsible supervisor. This notification form is partially filled out and is attached to this letter. We have also reviewed many hazardous waste to determine if additional hazardous waste codes are needed. This form is also required and must be signed by you or a knowledgeable, responsible supervisor. After checking and signing the forms, please copy for your files and return them to us. We have already set our computer to deactivate all hazardous wastes for which we have not received notification forms or where additional hazardous waste code forms are needed but not received. This means you cannot send usany of these wastes after August 8.until these forms have been returned. Thisis the only way we can be sure we get all the paperwork completed that is needed for compliance. In most cases (since we do not see large inventories of hazardous waste in the Division) you will have somewhere between 10 and 90 days to get your paperwork completed. We urge you not to wait until the last minute. Please review your waste streams and get the paperwork signed. Another good reason to complete the paperwork early is that by September 25 we will have to complete a second review. This review will be broader inscope and cover non hazardous as well as hazardous waste. We plan touse the same procedure (i.e., deactivate wastes until we get signed paperwork for the files) as we are currently using for this review. The keys are: 1. review the paperwork and the waste stream 2. sign the forms 3. copy them for your files 4. return the forms so we can accept your waste. AN OPERATING UNIT OF THE DOW CHEMICAL COMPANY Division Waste Generators -2- July 24, 1990 This may be confusing. It's something we must do and we cannot or do not want to erxceed the 90 day limit on storage. We will all try to help, so please call Bill Lane, Leonard Dodd, or me if you have questions. /f/, a/. XX'i D. A. Ktuelskie Environmental Operations Plant Bill Lane Environmental Operations Plant Leonard Dodd Environmental Operations Plant mg attach C>0 A 05581 3 CONFIDENTIAL LAND DISPOSAL RESTRICTIONS - NOTICE FOR INCINERATION Plant: _____________________________ Account: LA Waste Type Number: __________________________________________________ Contact: Phone: Waste Name: A waste with EPA Hazardous Code is being shipped to the Rotary Kiln for incineration or for appropriate disposal. This waste is subject to land disposal restrictions per the following: _________ Spent Solvent List (Attachment 1) California List (Attachment 2) "Third" List with set treatment standard (Attachment 3) Lab Pack Appendix IV/V (Attachment 4) T. C. Waste (Attachment 5) This waste contains the following constituents identified in Attachments 1 - 4 of 40 CFR 268 and of LAC 33:V.2213 and must be treated at least to the level specified below. Constituent Treatment Standard/Treatment Technology _I certify under penalty of law that I personally have examined and am familiar with the waste and that the lab pack contains only the wastes specified in Appendix IV to Part 268 or solid wastes not subject to regulations under Part 261. I am aware that there are significant penalties for submitting a false certification, including the possibility of fine or imprisonment. I certify under penalty of law that 1 personally have examined and am familiar with the waste through analysis and testing or through knowledge of the waste and that the lab pack contains only organic waste specified in Appendix V to Part 268 or solid wastes not subject to regulation under 40 CFR Part 261. I am DO A 055814 00NF1DFNTT AL aware that there are significant penalties for submitting a false certification including the possibility of fine or imprisonment. Authorized Representative Signature Print or Type Name __Date Title LS:cm 7/90 LS52 00 A 055815 CONFIDENTIAL REGULATORY REVIEW OF WASTE STREAMS WASTE STREAM TYPE NUMBER DATE OF REVIEW_______________ PLANT OR LOCATION WASTE NAME ON WCDS (PLEASE CHECK APPROPRIATE BOXES) INACTIVE WASTE ?TPEAMg t ] I HAVE REVIEWED THIS WASTE STREAM AND HAVE FOUND THAT IT IS NOW INACTIVE AND DO NOT EXPECT TO GENERATE IT AGAIN IN THE NEAR FUTURE. ACTIVE WASTE STREAMS (TOR CURRENTLY LISTED NON HAZARDOUS WASTES) [ ] I HAVE REVIEWEDTHIS WASTE STREAM IN REGARD TO THE TOXIC CHARACTERISTIC REGULATIONS AND HAVE FOUND THE WASTE TO BE NON HAZARDOUS [ ] I HAVE REVIEWEDTHIS WASTE STREAM IN REGARD TO THE TC REGULATIONS AND HAVE FOUND THAT THE WASTE IS NOW A HAZARDOUS HASTE. NEW HAZARDOUS WASTE CODES HAZARDOUS CONSTITUENTS CONCENTRATION OF THE HAZARDOUS CONSTITUENTS ACTIVE WASTE STREAMS (TOR CURRENTLY LISTED HAZARDOUS HASTES) [ ] I HAVE REVIEWED THIS WASTE STREAM IN REGARD TO BOTH THE THIRD THIRD REGULATIONS AND THE TC REGULATIONS AND HAVE FOUND THAT NO ADDITIONAL HAZARD CODES ARE REQUIRED. [ ] I HAVE REVIEWED THIS WASTE STREAM IN REGARD TO BOTH THE THIRD THIRD AND TC REGULATIONS AND HAVE FOUND THAT THE FOLLOWING ADDITIONAL HAZARD CODES ARE REQUIRED. NEK HAZARDOUS WASTE CODES HAZARDOUS CONSTITUENTS CONCENTRATION OF THE HAZARDOUS CONSTITUENTS ( 1 I HAVE REVIEWED THE ANALYTICAL DATA AND FOUND IT TO BE CURRENT. [ ) THE ANALYTICAL DATA HAS EXPIRED AND NEW ANALYSIS WILL BE RUN SHORTLY. I CERTIFY THAT THE INFEEMATION ON THIS REVIEW SHEET IS TRUE, ACCURATE, AND COMPLETE. SIGNATURE D0 A 055816 CONFIDFNTTAL DATE DO A 0 5 5 8 1 7 CONFTDFNTTAL TRAINING REQUIREMENTS HAZARDOUS WASTE GENERATOR Train Annually Formal Training Directed By Person Trained In Hazardous Waste Management New Personnel Train Within 6 Months 50 A 0 5 5 8 1 8 C Q N F T D F N T IA L TRAINING REQUIREMENTS HAZARDOUS WASTE GENERATOR Maintain Following Documents - Job Title Job Description Description Of Training Course Records Of Training Individual Signatures RO A 0 5 5 8 1 9 CONFTDFNTTAL PERMITTING REQUIREMENTS Hazardous Waste Stored For 90 Days Or More Requires A RCRA Permit Hazardous Waste May Be Stored For <90 Days Provided The Tank Or Container Is Emptied Every 89 Days Hazardous Waste Treatment Or Disposal Activities Require A RCRA Permit A 055820 CO NFIDFNTTAL PERMITTED HAZARDOUS WASTE FACILITIES PERMIT EFFECTIVE MAY 19, 1989 Environmental Operations Rotary Kiln Tanks, & Container Storage Solvents TOX & Tanks Vinyl II TOX & Tanks Northwest Landfill Block 80 Hazardous Waste Landfill DO A 0 5 5 8 2 CONFTDFNTTA HAZARDOUS WASTE FACILITIES TO BE PERMITTED Throxes Vinyl II Glycol I Chlorinated Methanes Classify Wastes Burned In Throxes Meet <90 Day Tank Requirements DO A 0 5 5 8 ? ? CO NFIDENTIAL TEMPORARY HAZARDOUS WASTE CONTAINER STORAGE Label Container Hazardous Waste Date Waste First Introduced Identify Waste Designate Storage Area Keep Container Closed DO A 0 5 5 8 2 3 CO NFIDENTIAL TEMPORARY HAZARDOUS WASTE CONTAINER STORAGE Maintain Adequate Aisle Space Inspect Containers Weekly Not Leaking Containers Closed Properly Labeled Stored <90 Days DO A 0 5 5 8 7 4 CO NFIDENTIAL INSPECTION RECORD The Inspection Record Must Include: Date Of The Inspection Time Of The Inspection Name Of The Inspector Notations Of Observations Date & Nature Of Any Repairs Or Remedial Actions Taken DO A 0 5 5 8 P 5 C 0 N F ID F N T IA 1 . TEMPORARY HAZARDOUS WASTE STORAGE TANKS Label Tank 'HAZARDOUS WASTE' Date Tank Empty Tank Every 89 Days Or Less Lowest Level Physically Possible Secondary Containment Tank Volume Plus 12 Inches Rain Routinely Check Tank's Integrity TEMPORARY STORAGE TANKS Dally Inspection Tank Labels Legible Tank System Leaks, Corrosion, Condition ol Equipment Secondary Containment Erosion, Gaps, Cracks, Pitting Cleanliness Ol Area Sump Dry, Dike Valves Closed Correct Instrument Readings Tank Levels, Pump Pressures Control Board Readings Match Gauges Correct Operating Conditions Level, Temperature, Pressure Level In Uncovered Tanks v -J C\ <X CO >ifi Vifl Z O UcJ <c ^U- o z8