Posted by Kyley Eagleson on Thu, May 23, 2013 @ 07:04 AM
If a generator accumulates more than the satellite limit, when should they date the container?
When exceeded, not started.
What is meant by 3-days?
Three days means three consecutive days. It does not mean working days or business days.
Originally the EPA proposed 72-hours as the time limit, but realized that determining when 72-hours elapsed would require the container to have both date and time labeled.
The leg of a PPE suit is hanging out from under the secured lid of a container. Is the container open or closed?
Open
Do containers in satellite areas have to comply with air emission standards?
No.
Do satellite containers need to be inspected?
The do not need to be although we recommend that you that you do so on a regular basis anyway.
Can a facility have more than one satellite accumulation area?
Yes.
The regulations do not limit the number of SAAs. Likewise, the regulations do not limit the total volume of waste that can be accumulated at various SAAs. Regulation only limits to 55 gallons (1 quart) per SAA.
Can a satellite accumulation area contain more than one container?
Yes.
It is permissible to have more than one container, as well as more than one waste type in a SAA. Good management practice dictates how this should be done. SAA is limited to a total volume of 55 gallons (1 quart).
When a facility has equipment that discharges hazardous waste to an attached container, do the attached containers need to be in compliance with satellite accumulation regulations?
Yes.
Are the dirty uniform bins considered satellite accumulations of hazardous waste? What about maintenance gloves?
No.
Contaminated wipes, gloves, or uniforms being commercially laundered and subsequently reused are not discarded; therefore, they are not a hazardous waste.
So, how many could you answer correctly?
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Posted by Kyley Eagleson on Tue, May 21, 2013 @ 07:59 AM
Today we are going to explore the ever exciting world of accumulation container standards, rules, and types! We will be focusing on the differences between and rules associated with satellite accumulation vs. 90-day. We will also be offering a short quiz available for download at the end of this post.
So to begin, we will talk about satellite accumulation. A generator can accumulate up to 55 gallons of hazardous waste in containers that are:
- At or near point of generations, and
- Under the control of the operator.
Acute hazardous waste accumulation is limited to 1 quart. All containers must be labeled with the words “hazardous waste” or with other words that accurately identifies the contents.
When containers in a satellite accumulation area exceed their limits of 55 gallons or 1 quart the container must be dated. The excess or the entire container then must be removed within 3 days. Otherwise, the site must be managed as a 90-day.
And as always, all container management standards apply; meaning that all containers must be in good condition, closed, labeled, and segregated for compatibility.
In a 90-day, a generator can accumulate for up to 90 days with no volume limits. There are, however, additional standards that must be complied with. Se the table below for a comparison of applicable standards.
As you can see, there are more standards that must be followed if you are a 90-Day generator. That said, it is important to note that this blog post is not intended to serve as an all-inclusive guide to standards. It is always best to check with local government and 40CFR for the most up-to-date information.
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Posted by Kyley Eagleson on Thu, May 16, 2013 @ 07:09 AM
I don’t know about you guys, but I have a few projects planned for this summer. My big one is repainting an old dresser and jazzing it up with some new hardware. I had considered getting a new one but then I thought, why not refurbish it? That got me thinking about one of my favorite things to post about…
Really cool upcycling projects! So I decided to go find a few more, great looking upcycling projects that you could try this summer.
1. Anything with wine corks! - This is a very popular craft. You can make anything from key chains to pot holders to bathmats or corkboards! The possibilities are only as limited as your imagination (and the number of wine drinkers in your house I guess).
2. Rake Wall Rack - Find an old rake and remove/cut off the handle. Hang the rake in your house with a nail, screw, or anything else you can find that will support the rake. Hang stemware from the rake. Impress your friends!
3. Decoupage – This is something I do a lot of! Cut photos and words out of your old magazines before you recycle them and you can use them to make a bevy of crafty items! I’m partial to photo frames and boxes but as you can see from the photos, you can do any number of projects!
And if you’re feeling exceptionally motivated / if you have an old vehicle laying around…
4. Turn Your Old Car into a Coop – This takes urban farming to a whole new level!
So what will you do this summer to help the environment and your home decoration?
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Posted by Kyley Eagleson on Tue, May 14, 2013 @ 07:26 AM
You know the phrase “you learn something new every day?” I sometimes wonder about that. I saw a card once that reflected my feelings pretty perfectly. It said something like, “I disagree with the idea that you learn something new every day. I think there are some days when I learn nothing at all, and in fact, forget some things.” But I am happy to say that today was one of those days when I did learn something!
Now for some of you this will probably not be new news but hopefully I will still provide you with some helpful information about what I learned. So, to alleviate the suspense (assuming you didn’t guess from the title of this post) I learned today that there is a difference between “empty” and “RCRA empty.”
Now I realize that regular hazardous waste generators may be thinking to themselves, “Yeah, we knew this…” But I found it pretty interesting and decided to look into it a little more. Generally, we think of something as empty when it appears empty to the naked eye. When properly empty as defined by the EPA, however, containers can be non-regulated even when residue remains.
So what makes a container RCRA empty? I learned that there are two general (common) answers as well as a third less common condition. To begin, we will determine if the waste was acutely hazardous.
What is an acutely hazardous waste?
An acutely hazardous waste is one that is P listed or designated with the sub-code H. In layman’s terms, acute hazardous waste is waste that is considered to present a substantial hazard whether managed properly or not. If your waste is acutely hazardous, there are a few ways you can make the container RCRA empty.
How do I make a container holding acutely hazardous waste RCRA empty?
The first way is applicable if your container has an inner liner. If it does you just need to remove it and you’re good to go (in terms of your container being empty, you still need to properly dispose of the liner). If your container doesn’t have a liner you need to triple rinse the container with an appropriate solvent. If triple rinsing is inappropriate you must check with the EPA and local government to determine an alternate method.
What if the waste is not acutely hazardous?
If the waste in your container is not acutely hazardous you can use practices that are commonly employed, industry-wide, to empty them to EPA regulated levels. Common methods for emptying are pouring, pumping, and draining. When emptying there are a few rules that constitute “empty.” Firstly, there can be no more than 1” remaining, no more than 3% waste for small containers and no more than .3% for large containers.
What is the third condition?
The third condition refers to gas cylinders. Containers holding compressed gasses are considered empty when the pressure in the container approaches atmospheric pressure.
What happens to residues in a container?
Residues which are removed from a container (like liners) are fully subject to RCRA and may or may not be considered hazardous based on waste determination. Residues in the container, however, are considered exempt and are non-regulated.
And as always, this information may not be all-inclusive and it is always best to check 40CFR and your state regulations for the most up-to-date information.
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Posted by Kyley Eagleson on Thu, May 09, 2013 @ 07:11 AM
Hazardous waste containers and storage areas are designed with specific intent. The container is for holding the waste and the storage area is to prevent escape of release from a container. The regulations intend to ensure that wastes are,
- Compatible with construction of the container,
- Compatible with other waste placed in the container,
- Stored in a containment area designed to prevent releases from the containers from reaching the environment.
One of the first things to make sure of is that your containers are in good condition. Containers that are deteriorating or leaking must not be used and waste must be removed or transferred from the defective containers.
After making sure your containers are in good shape, you must make sure that the container type is compatible with the type of waste held within. The term incompatible waste refers to a hazardous waste which is unsuitable for placement in a container because it may cause damage to the container or inner liner; or when mixed with other waste in the container under uncontrolled conditions might produce:
- Heat or pressure,
- Fire or explosion,
- Violent reaction, or
- Toxic dusts.
Containers used to store hazardous waste must be made of or lined with materials that will not react with the waste and are otherwise compatible with the waste. Incompatible waste must not be placed in the same container. This includes unwashed containers that previously held an incompatible waste or material.
It is not just in containers that you must think of compatibility, though. Incompatible wastes are to be kept separate from each other in storage. Incompatibles must be kept separate by dike, berm, wall, and separated by sufficient distance. It helps to remember the 2 row minimum rule. Incompatible materials must be 2 rows apart, separated by a row compatible to both.
Compatibility is so important because accidentally mixing incompatible wastes can have very dangerous ramifications. Always be sure to check and double check that you are not inadvertently mixing incompatible wastes. And remember, this information may not be all-inclusive and it is always best to check 40CFR and your state regulations for the most up-to-date information. Keep reading our blog for more information about containerized wastes.
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Posted by Kyley Eagleson on Tue, May 07, 2013 @ 07:34 AM
Have you missed the hazardous waste questions posts? We really went strong with them for a while! If you have, I have some good news for you.
Since readers seemed to appreciate the series we combined all the questions into a downloadable quiz file. This file contains the questions from each of the question posts:
This file is free for download and can serve as a great tool to help your company maintain compliance. The quiz is multiple choice and the answers are all at the end. Additionally, we provide a link at the end to our schedule of RCRA training seminars just in case you don't do as well as you thought you would.
Enjoy and good luck!
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Posted by Kyley Eagleson on Thu, May 02, 2013 @ 07:12 AM
I know I tried to say it before and was then brutally rebuked by Mother Nature but this time I feel certain, spring has sprung! Please don’t blame me if we have another freak snow storm though. So in celebration of what I’m hoping is the true cusp of spring / summer, I’d like to provide you with some fun, and environmentally friendly, activities and project ideas.
1. Make a quilt – Perhaps you chose to go through your closet and dresser during your spring cleaning activities and now you have bags and boxes full of old clothes sitting in wait for Goodwill. Well, if you don’t want to drive them away, you could always use the fabric to make a scrap quilt! Just cut up some of your favorite patterned (or non- patterned, both work) pieces into equal sized squares and sew it up. This would be a great weekend project and you could even get the kids in on it by having them arrange the squares for you.
2. Have a game day – Take a day to unplug and spend some time soaking up the newly returned sun! Power down your TV’s and game consoles and pick up cards or a board game. If you’re really feeling green, make your way to the sunniest room of your house so you can turn off the lights too!
3. Go backyard camping – You may not want to venture out into the wilderness quite yet (the evenings can still get cold) but backyard camping can be a great alternative! Get outside and cook dinner around a fire and assuming the weather holds, curl up in your tent for the night. It’s a great way for a little environmental adventure!
4. Plant a garden – Get ready for fresh summer produce by planting a garden of your very own. Even if you don’t have much of a green thumb you can find some low maintenance flowers to plant. Don’t let a lack of space stop you either, I fully intend to buy a tomato plant to keep on the back slab at my apartment! You always have options.
5. Take a walk – While this one doesn’t necessarily benefit the environment, it won’t hurt it either! Plus, if you walk somewhere you would have driven you really will help the environment. If you’re feeling extra motivated you could even jog or run, but that is strictly optional!
6. Make a birdhouse – This is another fun craft you could do with your kids. Even if they are still too small to help build they could help you decorate it and help pick where to hang it. Plus, you’ll be helping some potentially homeless birds!
7. Take it outside - This one goes back to turning off the TV’s and lights in your house again. Take a day and spend it outside basking in the glory of springtime! Remember, before long it may get too hot to enjoy for a full day.
So do you have any fun spring plans or projects? Tell us about them in the comments section!
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Posted by Kyley Eagleson on Tue, Apr 30, 2013 @ 07:56 AM
Throughout the coming weeks we will have several posts about container standards and management. Containers storing hazardous waste at permitted facilities are subject to the general facility standards as well as the specific container standards of 40 CFR 264/265.
When the EPA promulgated the unit-specific requirements (container standards), for hazardous waste containers, the Agency emphasized that although mismanagement of containers has caused some of the worst contamination, relatively few regulations would be needed to eliminate most of the problems. Today, I will be writing about some of the basics you need to know in order to maximize your container management efficiency.
To start, it is vital to note that all containers storing hazardous waste must comply with both state regulations and those regulations set forth by the federal government in 40CFR.
That said, the word container is a bit non-specific. At Heritage, we teach that a container is any portable device in which a material is stored, transported, treated, disposed of, or otherwise handled. Now you may be thinking, “That definition is pretty non-specific too.” That is true. The definition is intentionally broad so that it can encompass all the different types of portable devices that may be used to handle hazardous waste, such as:
- Drums
- Pails
- Tankers or
- Railcars, among possible others.
After looking into what items are available in which to store hazardous waste, we need to determine the definition of “storage.” Storing hazardous waste means holding it for a temporary period until it is treated, disposed of, or moved elsewhere. Again, this definition is intentionally broad in order to include any situation in which hazardous waste is held for any period of time.
It is important to remember that this information may not be all-inclusive and it is always best to check 40CFR and your state regulations for the most up-to-date information. Keep checking the blog for future posts about container design and compatibility.
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Posted by Kyley Eagleson on Thu, Apr 25, 2013 @ 07:18 AM
What is an aerosol can?
The basic aerosol can of today has not really changed since the 1920’s. It is a metal can in which two fluids are sealed. One fluid is the product that is to be dispensed and the other is the propellant. The propellant is a compressed gas that expands when the aerosol can is opened (generally by pushing a button or pulling a lever). The propellant forces the product through a tube in the can and out the nozzle. Many different products are dispensed in aerosol cans, from shaving cream to cooking spray or room fresheners. Although the cans these products come in may look different, the mechanism behind them is the same.
When is an aerosol can hazardous?
Due to regulations concerning Chlorofluorocarbons (CFCs) and Hydrochlorofluorocarbons (HCFCs) most aerosol cans today use a hydrocarbon propellant. While this type of propellant is less harmful to the ozone layer than CFCs and HCFCs were it is highly flammable.
If an aerosol can held a substance that is regulated as hazardous it must “drained or emptied to less than 3% by weight of the total capacity of the container (40 CFR 261.7)” or it is considered a hazardous waste.
That said, even aerosol cans that have been drained to less than 3% will likely still contain propellant (which can be reactive when combined with an igniting force) and as such will still be considered hazardous. So, unless a can is fully emptied of propellant it is still considered a hazardous waste and should be disposed of accordingly.
How should I dispose of my aerosol cans?
For a business, an aerosol can that has been both punctured and drained of its contents would meet the definition of scrap metal (40 CFR 261.1) and can be recycled. Regulations for puncturing change though and need to be checked on both a national and state level. If not punctured and recycled, a hazardous waste determination must be made and the can(s) must be disposed of appropriately.
For an individual or home, RCRA does not regulate how you dispose of your aerosol cans. If you would like to do the best / most environmentally friendly thing though you could take your old aerosol cans to a local household hazardous waste collection.
And remember, this post is meant to provide general information about managing aerosol cans. It is always important to consult the actual state and federal statutes and regulations before making any decisions that may impact regulatory compliance.
Looking for answers to Tuesday's Quiz Post?
30: c 31:d 32:b 33:a 34:b
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Posted by Kyley Eagleson on Tue, Apr 23, 2013 @ 07:04 AM
At long last we are finished with our series of posts dealing with hazardous waste! Remember, now that all 6 posts are live, you have a great 34 question quiz for you and your company or coworkers!
30. The maximum volume of non-acute hazardous waste that may be present in a satellite accumulation area is
a) None
b) One full container until it is moved and a second container being filled
c) 55 gallons
d) None of the above
31. DOT Security requirements apply to:
a) Haz Mat Carriers (“transporters”)
b) Haz Mat Shipper
c) Only Hazardous Waste Shipments
d) Both Haz Mat Carriers and Shippers
32. How long may a Conditionally Exempt Small Quantity Generator accumulate non-acute hazardous waste on site
a) One year as long as long the quantity on-site does not exceed 2200 pounds, but states may be more stringent
b) No time limit as long as long the quantity on-site does not exceed 2200 pounds, but states may be more stringent
c) 180 days as long as the quantity on-site does not exceed 2200 pounds, but states can be more stringent
d) None of the above
33. RCRA regulations have been in effect for how many years?
a) Over 25 years
b) About 20 years
c) Less than 10 years
d) Since 1970
34. Training conducted under RCRA meets all of the relevant requirements for shipping hazardous materials under DOT
a) True
b) False
Final answers can be found at the bottom of our "Is it hazardous waste... aerosol cans?" post.
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