Environically Speaking: Heritage Environmental's Blog

Land Treatment Units: Operations, Inspections, and Closure

Posted by Kyley Eagleson on Tue, Oct 21, 2014 @ 06:30 AM

Land_Treatment_Units_Operations,_Inspections,_and_ClosureLast week we wrote about land treatment units (LTUs) including what they are and how they are designed.  Today we would like to cover operation regulations, inspection and response actions, and closure guidelines. 

How are LTUs designed and operated?

The basic guidelines for design and operation of a land treatment unit can be found in 40 CFR 265.272.  These regulations read as followed:

“(a) Hazardous waste must not be placed in or on a land treatment facility unless the waste can be made less hazardous or nonhazardous by degradation, transformation, or immobilization processes occurring in or on the soil.
(b) The owner or operator must design, construct, operate, and maintain a run-on control system capable of preventing flow onto the active portions of the facility during peak discharge from at least a 25-year storm.
(c) The owner or operator must design, construct, operate, and maintain a run-off management system capable of collecting and controlling a water volume at least equivalent to a 24-hour, 25-year storm.
(d) Collection and holding facilities (e.g., tanks or basins) associated with run-on and run-off control systems must be emptied or otherwise managed expeditiously after storms to maintain design capacity of the system.
(e) If the treatment zone contains particulate matter which may be subject to wind dispersal, the owner or operator must manage the unit to control wind dispersal.”

According to the EPA, “these sections require the Regional Administrator or authorized state to specify certain parameters in the facility permit.”  Parameters to be specified include the rate and method at which waste is applied to an LTU, measures to be taken in order to control pH levels in soil, measures to enhance microbial and chemical reactions, and measures to control the moisture content of the treatment zone.  LTUs are not only subject to these regulations, however.  They also must control stormwater run-on and runoff.  

Do LTUs need to be inspected?

While there are no set inspection requirements for LTUs, the owner operator does have to maintain unsaturated zone monitoring in order to ensure the unit is meeting performance standards.  According to the EPA, “the purpose of unsaturated zone monitoring is to provide feedback on the success of treatment in the treatment zone and to determine if hazardous constituents are migrating out of the treatment zone (i.e., the monitoring program must be designed to determine the presence of hazardous constituents below the treatment zone).”

What this would generally mean is that the owner and operator of the LTU would need to monitor for the most stable hazardous constituents found in the waste placed in the treatment zone.  The EPA clarifies, however, that, ”unsaturated zone monitoring is not a substitute for groundwater monitoring. Both are required for land treatment units.”

How is an LTU closed?

According to the EPA, “When a land treatment unit is being closed, the owner and operator must maintain all operating parameters to continue the treatment processes, as well as maintain run-on and runoff controls and unsaturated zone monitoring. The major element of the closure procedure is placing a vegetative cover over the closing unit that is capable of maintaining growth without extensive maintenance. At the completion of closure, the owner or operator may submit the closure certification by an independent qualified soil scientist in lieu of an independent registered professional engineer. Closure and post-closure requirements are waived when the hazardous constituents in the treatment zone no longer exceed background levels.”

 

Quoted and EPA cited information (unless otherwise noted) for this blog post was gathered from the EPA document, Introduction to Land Disposal Units.”  As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations.  

How are Land Treatment Units Designed?

Posted by Kyley Eagleson on Thu, Oct 16, 2014 @ 06:30 AM

How_are_Land_Treatment_Units_DesignedAccording to the EPA, “owners and operators of land treatment units (LTUs) must devise a program and demonstrate its effectiveness given the design of the unit and characteristics of the area. In addition, the regulations require specific operating requirements to be met in the treatment program.  The requirements outlined for the treatment program, including design and operating criteria and unsaturated zone monitoring, stem from a treatment demonstration.”

The purpose of the treatment demonstration is for the owner / operator to adequately display the effectiveness of the land treatment unit at degrading or immobilizing the hazardous constituents in the waste placed there within.  A treatment demonstration can involve laboratory testing and / or field testing on a sample soil plot. 

What is a Treatment Demonstration? 

The EPA states that, “the Regional Administrator or authorized state uses information provided by the treatment demonstration to set permit standards. Interim status units are not required to establish a treatment program because the interim status regulations are self-implementing.”  In order for owners and operators to place waste in an LTU the waste must be rendered nonhazardous or less hazardous from placement.  The EPA has established a list of parameters that owners and operators must establish during the treatment demonstration.  These parameters include the following:  

  • “Specify the wastes that may be handled at the unit. In general, land treatment is confined to wastes that are primarily organic and that can be greatly reduced in volume by physical, chemical, and biological decomposition in surface soils. The owner and operator must be able to account for smaller fractions of heavy metals and persistent organic compounds by immobilizing those constituents…
  • Formulate a set of operating measures. The LTU must be operated in a manner that will maximize degradation, transformation, and immobilization of hazardous waste constituents….
  • Establish unsaturated zone monitoring. The purpose of this program is to make sure that treatment is occurring within the treatment zone and that all hazardous constituents are being adequately treated. The information provided from the monitoring can help the owner and operator "fine tune" the treatment process to maximize the success of the treatment. Unsaturated zone monitoring involves soil monitoring (e.g., obtaining soil samples) immediately below the treatment zone…
  • Define the treatment zone. This zone comprises the horizontal and vertical dimensions of the unsaturated zone in which the owner and operator intend to perform the actual treatment. The zone can be no deeper than 1.5 meters (5 feet) and the bottom of the zone must be at least one meter (3.2 feet) above the seasonal high water table.”

According to 40 CFR §264.273, “the owner or operator must design, construct, operate, and maintain the unit to maximize the degradation, transformation, and immobilization of hazardous constituents in the treatment zone. The owner or operator must design, construct, operate, and maintain the unit in accord with all design and operating conditions that were used in the treatment demonstration…

At a minimum the Regional Administrator will specify the following in the facility permit:

  • The rate and method of waste application to the treatment zone;
  • Measures to control soil pH;
  • Measures to enhance microbial or chemical reactions (e.g., fertilization, tilling); and
  • Measures to control the moisture content of the treatment zone.”

 

Quoted and EPA cited information (unless otherwise noted) for this blog post was gathered from the EPA document, Introduction to Land Disposal Units.”  As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations.      

Topics: Land Disposal Units, Land Treatment Units, LTU

What is a Land Treatment Unit?

Posted by Kyley Eagleson on Tue, Oct 14, 2014 @ 06:30 AM

What_is_a_Land_Treatment_UnitWe’ve done several posts in the past about land disposal units (LDUs); covering landfills, waste piles, and surface impoundments in detail.  While landfills, waste piles, and surface impoundments, and land treatment units all serve as the “grave” portion of the cradle-to-grave system set forth by the EPA, landfills, waste piles, and surface impoundments all share several regulatory requirements whereas land treatment units are very different in both purpose and management. 

What makes LTUs different?

According to the EPA, “land treatment involves the application of waste on the soil surface or the incorporation of waste into the upper layers of the soil in order to degrade, transform, or immobilize hazardous constituents present in hazardous waste.”  This differs greatly from landfills, waste piles, and surface impoundments because the primary goal of the aforementioned is to stop waste from migrating to the surface soil. 

In an LTU, the waste is treated “within the matrix of the surface soil.”  That said, the EPA mandates that any waste in an LTU be placed in the unsaturated zone of the soil.  This is the land that lies above the water table (the highest point of groundwater flow).  The success of an LTU is dependent upon the operational management of the unit because of this proximity to the groundwater.

Why use an LTU?

The goal of a land treatment unit is to allow the soil microbes and natural sunlight to degrade the hazardous waste.  Because of this, the design and operation standards are very different than those that landfills, waste piles, and surface impoundments face.  For example, “land treatment units generally do not use impermeable liners to contain wastes. Instead, units rely on the physical, chemical, and biological processes occurring in the topsoil layers. In a sense, these units can be viewed as an open system.”

In LTUs maintaining proper soil PH, carefully managing the rate of waste application, and controlling the surface water runoff are imperative to the unit running smoothly.  “Because placement of hazardous waste in a land treatment unit is considered land disposal, land disposal restrictions (LDR) standards must be considered. If the hazardous waste does not meet the applicable treatment standard prior to placement in the land treatment unit, the unit owner or operator must obtain a no-migration variance before applying any hazardous waste to the unit.”

Keep checking our blog for more posts on land treatment units including design and operating procedures, inspection and response, and closure practices. 

 

Quoted and EPA cited information (unless otherwise noted) for this blog post was gathered from the EPA document, Introduction to Land Disposal Units.”  As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations.      

Topics: Land Disposal Units, Land Treatment Units, LTU

How are Hazardous Waste Landfills Designed and Managed?

Posted by Kyley Eagleson on Thu, Oct 09, 2014 @ 10:17 AM

How_are_Hazardous_Waste_Landfills_Designed_and_ManagedWhile we’ve covered certain aspects of Land Disposal Restrictions (LDR) in the past, we’ve not yet talked about how landfill cells are designed and managed.  For those who may not know, hazardous waste landfills are large areas of land divided into individual cells.  Perhaps the most important thing to note is that because hazardous waste landfills are final disposal sites for much of out hazardous wastes, they must continue to be monitored during their whole active life.  This includes closure and post-closure monitoring. 

How are landfill cells designed?

Much like the minimum technological requirements (MTRs) for waste piles and surface impoundments, hazardous waste landfills must have a double-liner, a leachate collection and removal system (LCRS), a leak detection system, and actual leakage reporting (ALR).  Additionally, landfills, like waste piles, must have a second LCRS above the top liner of the cell.  Finally, “landfills have to have stormwater run-on and runoff controls to prevent migration of hazardous constituents for at least a 25-year storm and a cover to prevent wind dispersal.”

How are landfills inspected?

Again, the inspection and response plans for hazardous waste landfills are nearly the same as those for surface impoundments.  This includes a response action plan in the event of the ALR being exceeded as well as a construction quality assurance (CQA) program.  In addition to having these items in place, a generator or owner / operator must perform monitoring and inspections.  “As with surface impoundments and waste piles, these requirements ensure that the unit is maintained in good working condition and that any problems are promptly detected.

How are landfill cells closed?

When a landfill cell is full it must be closed.  Since landfill disposal is typically a permanent situation the closure and post-closure regulations are somewhat different than those for other land-based units.  The EPA provides the example of the “requirement for a final cover over the landfill that can provide long-term minimization of liquid migration through the closed landfill, promote drainage, accommodate settling, and function with a minimum amount of maintenance.”

Owner / operators must also comply with the post closure requirements in Parts 264/265.117 through 264/265.120 relating to actions like monitoring and maintenance.  

Lastly, owner / operators have to “maintain the final cover, leak detection system, and groundwater monitoring system, as well as prevent run-on and runoff from damaging the final cover and protect the surveyed benchmarks (i.e., location and characteristics) of the landfill.”

Do any wastes require special treatment?

Like waste piles and surface impoundments, landfills must oblige with certain restrictions when dealing with ignitable, reactive, incompatible, or dioxin-containing wastes.  Unlike other units, however, landfills are prohibited from placing bulk or noncontainerized liquid hazardous waste or hazardous waste containing free liquids anywhere in the landfill.  Even placement of nonhazardous liquids is basically prohibited. According to the EPA, “there are only certain situations when containers holding free liquids can be placed in a landfill (e.g., small containers such as ampules, containers that are products such as batteries, or labpacks).  If sorbents are used to treat hazardous wastes so that the waste no longer contains free liquids, the owner and operator must use nonbiodegradable sorbents.”

Are there any requirements for containers in landfills?

“To prevent significant voids that could cause collapse of final covers when containers erode, and to maintain and extend available capacity in hazardous waste landfills, containers placed in a landfill must be either at least 90 percent full or crushed, shredded, or in some other way reduced in volume, unless the containers are very small, such as ampules (§264/265.315). 

Finally, there are special standards for lab packs or overpacked drums being placed in a landfill(§264/265.316). Lab packs generally contain small containers of a wide variety of hazardous wastes in relatively small volumes that are packed in sorbent material to prevent leaking. This sorbent material must be nonbiodegradable.”

 

Quoted and EPA cited information (unless otherwise noted) for this blog post was gathered from the EPA document, Introduction to Land Disposal Units.”  As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations. 

Topics: Land Disposal Units, LDR, Hazardous Waste Landfill

What is a Waste Pile?

Posted by Kyley Eagleson on Tue, Oct 07, 2014 @ 07:53 AM

What_is_a_Waste_PileIn the past we have covered the subject of surface impoundments in some detail.  From design and operation to inspection and response actions, we have taken a close look at what that type of land disposal unit is used for and how one must be managed.  Today we are going to take a similar look into hazardous waste piles. 

The regulations concerning waste piles can be found in Part 264/265, Subpart L of 40CFR.  Basically, a waste pile is a pile of noncontainerized solid, non-flowing hazardous waste.  Waste piles are not a disposal method but merely serve as a storage and/or treatment option for generators.  Because they are not an end-of-life stage for waste, Subpart L does not contain post-closure care regulations.  However, waste piles do sometimes need to close with waste still in place.  If this happens, the waste pile is closed as a landfill and is susceptible to all applicable regulations.  This is discussed in more detail below.

According to the EPA, “owners and operators of permitted waste piles that meet special requirements are subject to reduced regulation.  Specifically, the waste pile must be located inside or under a structure and not receive free liquid, protected from surface water run-on, designed and operated to control dispersal of waste, and managed to prevent the generation of leachate.  If these standards are met, the owner and operator of the permitted waste pile are exempt from groundwater monitoring requirements, as well as the design and operation requirements for waste piles.”

How are waste piles designed?

The minimum technological requirements (MTRs) for waste piles are just about the same as those of surface impoundments.  These requirements include the need for new units, lateral expansions, and replacement units to be equipped with a double liner and leachate collection and removal system (LCRS).  Additionally, waste piles, with some exceptions, require a second leachate collection and removal system above the top liner. 

A permitted waste pile that is not subject to MTR (things like units, lateral expansions, or replacements that were commenced before July 29, 1992) only needs to have one liner and meet basic LCRS requirements.  The EPA states, “interim status waste piles that are not subject to MTR are subject only to liner, run-on, and run-off controls if leachate or runoff is found to be a hazardous waste.”

How do you close a waste pile?

As mentioned earlier, a waste pile is a storage or treatment area as opposed to an end stage disposal option for hazardous waste.  Because of this, prior to closure all waste residues and contaminated subsoils and equipment must be removed or decontaminated at closure.  According to the EPA, “if an owner or operator removes or decontaminates all waste residues and makes all reasonable efforts to remove or decontaminate all structures and soils and finds that some contamination remains, the waste pile will then be subject to the closure requirements for landfills, including post closure care.”

Are there special requirements for different kinds of wastes?

As with many storage options, RCRA puts special requirements on storing ignitable or reactive wastes in waste piles because these types of materials “require continuous protection from conditions that could cause them to ignite or react.”  Similarly, there are regulations prohibiting the placement of incompatible wastes or materials in the same waste pile unless certain precautions are taken to avoid incident.  Lastly, if an owner / operator plans to manage dioxin-containing waste he or she must have a special management plan approved by the Regional Administrator or authorized state.

What’s the difference between a waste pile and a containment building?

According to the EPA, “containment buildings, sometimes characterized as ‘indoor waste piles,’ are units used to hold noncontainerized piles of hazardous waste.  The difference between waste piles and containment buildings, from a regulatory standpoint, is that containment buildings are not land disposal units.  For this reason, containment buildings are designed with a container system rather than a liner and leak detection system.”

 

Quoted and EPA cited information (unless otherwise noted) for this blog post was gathered from the EPA document, “Introduction to Land Disposal Units.”  As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations. 

Topics: hazardous waste storage, Waste Piles,

Tips for Hazardous Waste Container Inspections

Posted by Kyley Eagleson on Thu, Oct 02, 2014 @ 08:30 AM

Tips_for_Hazardous_Waste_Container_InspectionsYou may remember from our post and eBook on the Top 10 Hazardous Waste Generator Violations that “Failure to Perform Weekly Inspections of Hazardous Waste Storage Areas,” is among the most common ways generators violate EPA regulations. 

Weekly container inspections are imperative to protect you, your company, and the health and safety of the public.  By performing your weekly inspections you can identify any issues that may arise and stop sills before they happen.

The EPA recommends that companies develop and maintain a standard inspection checklist that can be used during each weekly inspection.  This checklist should be detailed and include both the labeling and management procedures in place at your facility. 

We have prepared a checklist (with some additional tips) which can be downloaded by clicking the button below. 

This checklist can be modified to fit the needs of your facility but remember that at the very list you need to address the following:

  • Any leaks or staining coming from containers;
  • Condition of your containers including noting any dents, bulging, and / or corrosion; 
  • Proper labeling—this should include a clearly marked start date as well as the words “Hazardous waste.”  Any other relevant information about the waste should also be indicated on the label.
  • Management practices such as aisle space and drum stacking.

Remember, these inspections are very important in both protecting your company from committing a violation and ensuring the protection of human health and the environment.  Inspections should be detailed and methodical and should always be performed by a fully trained individual.

The EPA provides the following tips for conducting your weekly container inspections:

  • “Follow the inspection checklist – make detailed notes if you find something wrong.
  • Be thorough. Check the tops of drums to look for waste residue or corrosion.
  • Walk all the way around containers – check entire storage area.
  • Check containment area for stains.
  • Note anything unusual in containment area – even if it might not be a problem.
  • If problems are found, get the problem taken care of immediately.
  • Keep a logbook of the facility’s inspection checklist.”

 

Quoted and cited information for this blog post (unless otherwise noted) was gathered from the EPA Handbook for Hazardous Waste Containers.  As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations.

Topics: container management, Hazardous Waste, Container Inspections,

Tips For Managing Incompatible, Ignitable, and / or Reactive Wastes

Posted by Kyley Eagleson on Tue, Sep 30, 2014 @ 07:11 AM

Tips_For_Managing_Incompatible,_Ignitable,_and_Reactive_WastesWhen managing containerized wastes that are incompatible, ignitable, or reactive there are even stricter regulations that must be adhered to.  According to §265.177, “a storage container holding a hazardous waste that is incompatible with any waste or other materials stored nearby in other containers, piles, open tanks, or surface impoundments must be separated from the other materials or protected from them by means of a dike, berm, wall, or other device.”  So in layman’s terms, if a generator has containers that are holding wastes which are incompatible he or she must physically separate the two waste types in order to keep them from contacting and potentially reacting with other wastes or materials. 

In addition to this, there are special requirements for ignitable or reactive wastes.  Firstly, these types of wastes must be stored at least 50 feet from a facility’s property line.  You may have seen that many facilities stack their drums along the fence line in order to maximize storage space; this, however, is not an option for storing ignitable or reactive wastes.  The reasoning behind keeping these types of waste well within the boundary lines of a facility are twofold.  Firstly, they reduce the risk of the general public being able to reach or come in contact with the waste (additionally protecting them from any harm in the chance of an explosion), and secondly, if a release of the hazardous waste occurs the distance will help to prevent waste from migrating offsite.  Besides the distance issue, there are a few more key regulations to follow.

According to 40CFR §265.17(a), “the owner or operator must take precautions to prevent accidental ignition or reaction of ignitable or reactive waste. This waste must be separated and protected from sources of ignition or reaction including but not limited to: Open flames, smoking, cutting and welding, hot surfaces, frictional heat, sparks (static, electrical, or mechanical), spontaneous ignition (e.g., from heat producing chemical reactions), and radiant heat. While ignitable or reactive waste is being handled, the owner or operator must confine smoking and open flame to specially designated locations. “No Smoking” signs must be conspicuously placed wherever there is a hazard from ignitable or reactive waste.”

To break that down, wastes that are ignitable or reactive must be managed to prevent fire or explosions. At a minimum this means a generator needs to keep these types of waste away from:

  • Fire;
  • Hot surfaces such as machinery engines;
  • Sunlight or radient heat;
  • Frictional heat (keep drums stationary to help with this, never drag or pull drums along the ground);
  • Cutting and welding operations;
  • Sparks from static electricity or electrical operations;
  • And in the case of some reactive wastes, water.

And finally, smoking must be banned and signs stating “No Smoking,” must be posted in all areas where reactive or ignitable wastes are managed. 

As far as best management practices go, the EPA provides the following advice:

  1. “Use a funnel or hose to add or transfer wastes to drums. This will prevent spills. Remember to rinse the funnel and characterize the rinse water (a dedicated funnel would not have to be rinsed).
  2. If you notice a leak, or a container is in poor condition, transfer the waste to a new container immediately.
  3. Keep containers cool and dry.
  4. Make sure all container storage areas are clearly marked -- keep ignitable/reactive wastes in their own area.
  5. Don’t stack ignitable/ reactive wastes.
  6. Make sure to open and close steel drums with a spark proof bung wrench.
  7. Don’t push, roll, or drag containers. Use the right equipment to move the drums.
  8. Make sure the drums are easy to reach – keep an open aisle space so that people and equipment can move freely.
  9. Don’t drive equipment (trucks, forklifts) into container storage areas unless you are moving containers.
  10. Keep the containers in a ‘containment area’ to hold spills. Containment can be provided by dikes, berms, or walls.”

  

Quoted and cited information for this blog post (unless otherwise noted) was gathered from the EPA Handbook for Hazardous Waste Containers.  As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations.

Topics: container management, Containerized Waste, containerized hazardous wastes

What is an EPA ID Number and How Do I Get One?

Posted by Kyley Eagleson on Sat, Sep 27, 2014 @ 06:27 PM

EPA ID NumberAccording to the EPA, “The Resource Conservation and Recovery Act (RCRA) requires individuals who generate or transport hazardous waste, or who operate a facility for recycling, treating, storing, or disposing (TSD) of hazardous waste, to notify EPA or their authorized State waste management agency of their regulated waste activities and obtain a US EPA Identification (ID) Number (also known as a RCRA ID Number). Handlers of some Universal Waste, Used Oil, and Boilers/Industrial Furnace may require a US EPA ID Number, too. If you are regulated and do not comply with the RCRA notification requirements, you may be subject to civil and criminal penalties.” [1]

EPA ID numbers are specific to individual sites (except when they are issued to transporters) and permanent.  There is an exception to the permanency in the case of provisional numbers which last for just 90 days and can be used in case of emergency or temporary one time clean-ups.  After the 90 days they are no longer valid and are deleted from the national registry.

What if our site moves?

EPA ID numbers do not move in the event that the owner / operator should relocate (unless the owner or operator is a transporter).  EPA ID numbers are so important because they help the EPA to track wastes through the entire cradle-to-grave cycle which follows waste from the point of generation to the point of disposal.  So, “Once a US EPA ID number is assigned to a specific physical location, it belongs solely to that location and will belong to any owners/operators at that location.” [2]

Should a generator decide to move the location of their operations (even if it is just to a different place in the same town) they would need to inactivate their old ID number for the former location and request a new ID number for their new location.  The EPA does note that, “If at the new location, a RCRA hazardous waste ID number had previously been issued to the former owner / operator, the number for that physical location will then be assigned to the new requester.” If not you would simply need to fill out a form as normal.

What forms do we have to fill out?

The EPA provides the Notification of Regulated Waste Activity (EPA Form 8700-12) and associated instructions in order to help these generators, transporters, and individuals determine whether or not they need to notify the EPA or authorized state of their regulated waste activities.  If they do, they must submit the RCRA Subtitle C Site Identification (Site ID) Form including the following:

  • “Initial Notification of Regulated Waste Activity
  • Subsequent Notification of Regulated Waste Activity
  • First RCRA Hazardous Waste Part A Permit Application
  • Revised RCRA Hazardous Waste Part A Permit Application
  • Hazardous Waste Report
  • Notification for eligible academic entities opting into or withdrawing from managing laboratory hazardous wastes pursuant to 40 CFR Part 262 Subpart K (if in an eligible State)
  • Notification for facilities managing hazardous secondary material pursuant to 40 CFR 260.42 (if in an eligible State)” [3]

Remember, some states have additional or different requirements than the Federal requirements.  It is always best to check with your state government in addition to the EPA.

“In order to determine if your location already has been assigned a US EPA Hazardous Waste ID number, look in EPA's Envirofacts Warehouse database by the physical location first (be sure to put in the State you want to search within).” [4]

 

As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations.    

Topics: EPA ID Number, Getting an EPA ID Number, EPA

Satellite Accumulation Areas vs. 90-Days: Part 2

Posted by Kyley Eagleson on Thu, Sep 25, 2014 @ 09:50 AM

Satellite Accumulation Areas vs. 90-Days: Part 2In the part one post on this subject we mentioned that the allure posed by less stringent regulations in Satellite Accumulation Areas (SAAs) can be problematic for generators who might misclassify their accumulation areas as SAAs ­instead of the more regulated 90-day areas.  Since this is a violation of EPA regulations it is imperative that generators know not only the difference between the two storage area types but also what must be done at each.

What is the difference between an SAA and a 90-Day?

A 90-day storage area is different from an SAA because it is an area where wastes can be stored for less than 90 days without a permit.  An SAA has no strict time limit associated with it, just a quantity limit.  Additionally, the time clock for wastes stored in an SAA does not start until the waste is moved to the waste storage area, in this case a 90-day.  So the two differences between SAAs and 90-days is the amount of waste that can be stored and the length of time it can be stored before needing to be treated or shipped offsite for management. 

How should containers be managed in a 90-Day?

As stated by the EPA, “The moment that waste is placed in the container, containers holding hazardous waste must be managed to prevent spills of hazardous waste.”  The best way to prevent spills is by making sure that your containers are in good condition before, during, and after waste is placed in them.  Containers in good condition should be free of dents and corrosion (which weaken the container), free of leaks, structurally sound, and devoid of bulges. 

According to §265.171, “If a container holding hazardous waste is not in good condition, or if it begins to leak, the owner or operator must transfer the hazardous waste from this container to a container that is in good condition, or manage the waste in some other way that complies with the requirements of this part.”

What if the containers in the 90-Day are already filled?

Companies that generate and store hazardous waste should have written procedures in place detailing how containers should be managed.  Additionally, all employees should be trained in the procedures.  At minimum the EPA requires that generators:

  • Keep containers closed at all times, except when…adding or removing waste from the container;
  • Be careful when…handling the containers. [Generators] must open, handle, and store containers to prevent ruptures or leaks.  For example, use drum grapplers to lift and move drums -- don’t hand-roll the drums from one area to another; and
  • [Take note] if the container begins to leak, or you notice dents or bulges, [if this happens] transfer the waste to another container.

In addition to all of this, generators must also prevent reactions of ignitable and / or incompatible wastes.  We will cover this topic in an upcoming blog post.

  

Quoted and cited information for this blog post (unless otherwise noted) was gathered from the EPA Handbook for Hazardous Waste Containers.  As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations.

 

Topics: satellite accumulation area

Satellite Accumulation Areas vs. 90-Days: Part 1

Posted by Kyley Eagleson on Thu, Sep 18, 2014 @ 07:20 AM

Satellite Accumulation Areas vs. 90 DaysIn Tuesday’s post we mentioned that the labeling and marking rules can be different for containers in Satellite Accumulation Areas (SAAs).  We will cover that (as well as some other specifics of SAAs) in today’s post.  It’s important to cover the guidelines for SAAs prior to covering those for 90-days so generators can make sure they are managing their accumulation areas properly. 

According to 262.34(c)(1), “a generator may accumulate as much as 55 gallons of hazardous waste or one quart of acutely hazardous waste listed in 261.33(e) in containers at or near any point of generation where wastes initially accumulate, which is under the control of the operator of the process generating the waste, without a permit or interim status and without complying with paragraph (a) of this section provided he:

  • Complies with 265.171, 265.172, and 265.173(a) of this chapter; and
  • Marks his containers either with the words “Hazardous Waste” or with other words that identify the contents of the containers.” 

So in laymen’s terms, an SAA can be utilized to store up to 55 gallons of hazardous waste (or up to 1 quart of acutely hazardous waste) for an unlimited time and with only some of the requirements needed for 90-day areas.  In order to store waste in an SAA the EPA requires that you:

  • Keep your containers in good condition,
  • Ensure that the waste being stored is compatible with the container type,
  • Keep containers closed unless you are adding or removing waste,
  • Make sure you handle containers in such a way that you are preventing leaks or spills, and
  • Mark containers with the words “Hazardous Waste,” or other identification of contents.

The less stringent and numerous regulations for SAAs attract a lot of generators which can cause problems.  Most often, these problems arise from generators storing in waste they have designated as an SAA but which is not actually applicable to that designation.  For an accumulation area to be an SAA very specific requirements must be met.  Firstly, only waste which is generated at the SAA can be stored there.  An SAA cannot be used as “temporary staging areas for wastes collected from other areas.”  Secondly, an SAA must be located at or near the point of generation.  So if waste is generated in a lab the containers should also be located in the lab.

If a generator accumulates more than the limit of 55 gallons of hazardous waste (or 1 quart of acute hazardous waste) at an SAA the EPA requires that they:

  • “Mark the container holding the excess accumulation of hazardous waste with the date the excess amount began accumulating,” and,
  • “Move the container holding the excess accumulation to a container storage area within 3 days.”

And remember, if a generator incorrectly manages a 90-day storage area as an SAA they will be in violation of EPA regulations.  For more information about managing waste in 90-day areas keep reading our blog!

 

Quoted and cited information for this blog post (unless otherwise noted) was gathered from the EPA Handbook for Hazardous Waste Containers.  As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations.

Topics: container management, SAA, satellite accumulation area, Waste Areas

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