HOWELL INSTITUTE

 


Table of Contents:

 

 

SCOPE OF RCRA PROGRAM

The RCRA program applies to all owners and operators of  facilities that generate, transport, treat, store or dispose of hazardous waste.  More specifically, it covers the following: 

–         Hazardous Waste Injection Wells*

–         Incinerators

–         Boilers and Industrial furnaces

–         Hazardous Waste Tanks

–         Surface Impoundments*

–         Underground Storage Tanks containing hazardous materials or petroleum products

–         Waste Minimization requirements

–         Mining wastes*

–         Imported wastes*

–         Exported Wastes*       

–         Recyclable materials*

–         Remediation Wastes

–         Universal wastes (e.g., batteries, fluorescent bulbs, lamps, thermostats, etc.)

–         Groundwater

–         Waste piles*

–         Containers

–         Landfills*

–         Land treatment facilities*

–         Containment buildings*

–         Recordkeeping and reporting

–         Drip Pads*

–         Manifest Records

–         Annual Hazardous Waste Reporting

–         Contingency Plans (i.e., for emergencies involving hazardous waste facilities)

–         Personnel Training

–         Spills

–         Waste Analysis Plan

–         Financial Responsibility

–         Air emission standards for equipment leaks, process vents, and tanks, surface impoundments and containers

–         Land Disposal Restrictions covering every hazardous waste

–         Wood preserving waste*

–         Hazardous debris

–         Corrective Action management Units (CAMUs)

–         Miscellaneous units*

–         Closure of hazardous waste facilities

–         Post-closure care of hazardous waste facilities

–         Used oil

–         Interim Status facilities

–         Hazardous waste munitions and explosive storage*

–         Military munitions*

–         Citizens right to participate in the process

*Note: *The items with asterisks are not currently applicable to PPG

 

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Hazardous Waste

 

Hazardous waste is an EPA “listed waste” or a waste that exhibits any of four characteristics:  ignitability, corrosivity, reactivity, or toxicity.

Examples of Listed Waste

  • Partially filled containers of waste paint

  • Waste paint thinner/waste paint solvent (used or unused)

  •  Waste spent solvent used for degreasing

  • Material contaminated with spilled hazardous material (mercury, solvents, etc.,.)

  • Mercury sulfide filter cake

  • Incinerator feed material

  • Used filters for Perchlor, Tri-Ethane, or other products

  • Reactor Still Bottoms

 

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There are Three Major Goals of RCRA
  1.  To protect human health and environment

  2. To reduce waste and conserve energy and natural resources

  3. To reduce or eliminate the generation of hazardous waste.

 

 

Handling Hazardous Waste
  • About 1200 employees trained annually

  • Those whose job involves handling or treating hazardous waste also receive on the job training

  • Container must be compatible with contents   

  • Containers must always be closed

  • Proper personal protective equipment must be worn depending on the hazard. 

  • Proper waste ID label and DOT label must be in place prior to addition of waste or shipment


Tighten Bung with Bung Wrench


Waste ID Label

DOT Shipping Label

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Specific Guidelines for Drums
  • Drums MUST be sealed with a binder ring, bolt and lid or a flip-top lid depending upon the type of drum and the drum contents.

  • Drums MUST be inspected for signs of deterioration, leaks, bulges and proper lid-securing             ability  before adding waste.

  • Incompatible wastes MUST always be segregated when working with liquid waste.

  • Liquid waste destined for a disposal facility must only contain what the manifest says it contains, and can only be shipped in approved  drums.

  • Drums are never stacked more than 2 high

  • Drums are secured when transferred

  • Note storage over concrete containment

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Bulk Solids : Roll-Off Boxes
  • Inspect bulk containers weekly and document.  All dump and roll-off doors must be equipped with security bolts, chains or other locking mechanisms in the event the primary locking system fails.  Box liners must be used unless otherwise specified.

  • Only waste material described to the disposal facility is to be placed in the bulk container.

  • No free liquids are to be present in bulk shipments so loading should not occur during rainfall unless the container is under a covered area.  Containers MUST be securely covered with waterproof tarps for storage and transportation.

  • Waste material should be evenly distributed over the length and width of the container and carefully loaded to prevent contamination of the outside of the container.

  • Due to weight restrictions, do not fill the box higher than 1/2 to 2/3 the depth of the box.

  • Properly label and date the bulk container when the waste is initially put into the box.                                                                                       
Two of the 
Four
Waste ID
Labels 


Waterproof Tarp

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Bulk Liquids

  • Closely inspect all tanks daily and document
  • Secondary containment with impervious coating is required
  • Tank repairs have to be certified
  • Do not use portable tanks or vacuum trucks for “storage” of hazardous wastes.

 

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HSWA
Hazardous and Solid Waste Amendment
1984

  • This is the federal statute amending RCRA.  It expanded and strengthened the regulation of hazardous and solid wastes.

  • It outlines a phased approach to determine the nature and extent of releases of hazardous waste or constituents from regulated units, solid waste management units and other source areas and to gather all necessary data to recommend Corrective Measures Study.

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RESOURCE CONSERVATION AND RECOVERY ACT REMEDIATION PROCESS

Started 1990

 

Ongoing

 

Future Activities

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Timeline / Status

  • 1980 - EPA Promulgates RCRA regulations and PPG applied for interim status

  • 1982 - Interim status was granted to PPG

  • 1984 - Significant change or amendments made to regulations by EPA and are still in place today

  • 1985 - PPG applies for final RCRA permit to governing agencies

  • 1986 - Successful trial burn on incinerators, complied with new tank regulations

  • 1990 - Proposed final permit issued to PPG by LDEQ

  • 1990 - PPG appealed some conditions in the permit and have worked cooperatively with the agencies to resolve.  Issues are still not resolved due to turnover in personnel, closure and resulting permit modifications in some facilities, low priority with agency due to acceptable operation.

  • 2001 - PPG performs more trial burns to demonstrate compliance with regulations.

Present - PPG continues to operate within permit conditions in appealed permit, air permits, awaiting issuance of final RCRA permit


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