Monthly Archives: January 2010

Disposal of electronic wastes

EPA has no specific rules about the disposal of electronic wastes. The general rules on the determination of hazardous wastes apply here. If your electronic waste is a RCRA solid waste (and it is), does it exhibit any of the four hazardous waste characteristics (ignitability, reactivity, corrosivity and toxicity)?

Pay attention to the toxicity characteristic. Most color CRTs contain high levels of lead and lead is one of the TCLP (Toxic Characteristic Leaching Procedure) chemicals. If the lead concentration of Lead in your CRT is greater than 5.0 ppm, it is a hazardous waste according to RCRA.

Many printed circuit boards may also contain cadmium , chromium, lead and silver. All of these are on the TCLP list. If the PCB fails the TCLP test, it must be disposed of as a hazardous waste.

Many states also have their own guidance on how to manage your electronic wastes. Colorado is a good example. Here is a document from the state’s agency on how to handle your electronic wastes. Always check with your own state’s environmental agencies. Here is a link to all of them.


How to neutralize your hazardous waste without a permit

Let’s say you have a waste that is hazardous solely because it exhibits the corrosivity characteristic (a D002 characteristic waste), you can neutralize it chemically in a tank or container prior to discharging it through a permit under the Clean Water Act. This is known as the Elementary Neutralization Unit Exemption.

This exemption will not apply if your waste also exhibits other hazardous characteristics (such as ignitability, toxicity or reactivity) or if it is a listed hazardous waste. Under this exemption, the unit (tank or container) where the neutralization occurs is exempt from RCRA standards. However, any sludge that comes out of this process is not exempt. If the sludge exhibits any hazardous characteristic, it will need to be managed as hazardous waste under RCRA.

Another point top remember is that if you have a separate container that is holding your D002 waste waiting to be neutralized, that container is NOT a treatment unit.neutra

Under this Federal exemption, you will not need to obtain a CRA Part B permit in order to treat your hazardous waste. Note that not all states have adopted this exemption. So always check with your state agencies.

Preparedness and Prevention Requirements

Both large and small hazardous waste generators are subject to the provisions of Part 265, Subpart C of RCRA – which calls for the generators to prepare for and prevent chemical accidents at the place where they store hazardous wastes. Subpart C requires the following:

  1. An alarm or communication system that is capable of providing emergency instructions to employees.
  2. A two-way communication system at the waste storage area.
  3. Fire fighting equipment such as fire extinguishers, water hose stations, automatic sprinklers and spill control and decontamination equipment.
  4. Regular testing of the equipment in 3 to ensure that they work.
  5. Adequate aisle space in the waste storage area to enable emergency personnel to get to the source of the emergency.
  6. Procedures that will minimize the possibility of fire, explosion or spills.
  7. Coordination with local authorities (fire department, police department and local hospitals) on how emergencies will be addressed.

It is very common for an inspector to find deficiencies in this area. Either you have a two-way telephone system or you don’t. Either you have adequate aisle space or you don’t. If your equipment is not working or in bad shape, the inspector will notice that too.

These are all low-hanging fruits for the inspectors. That’s why they are one of the most commonly cited RCRA violations.

Just for fun, take our general environmental quiz. Only you know the test score.

Counting oil in an SPCC Plan

Someone asked me the other day if he needed to count the fuel oil in his backup generator towards the 1320 storage threshold for preparing an SPCC.

My answer was yes – if the “oil capacity” in his generator is 55 gallons or more and he is the “owner and operator” of the generator. Note that in SPCC, the term “capacity” refers to the shell capacity – not the actual amount of oil in the container.

See tables below. They are taken from EPA’s Guidance for Regional SPCC Inspectors.

Test your environmental knowledge

You can test your knowledge of basic environmental regulations here.

It is done in the privacy of your office/home.

Only YOU know the results.

How to do an environmental hazard analysis

As environmental professionals, there is much we can learn from our colleagues on the health and safety side.

An essential part of an effective health and safety program is job hazard analysis. The purpose here is to identify safety issues that may be present during the performance of a specific task. The hazardous analysis takes the form of a series of five questions:

  • What can go wrong?
  • What are the consequences?
  • How could it happen?
  • What are other contributing factors?
  • How likely is it to happen?

For example, if you were to perform a job hazard analysis at a job where an operator is working with a stationary rotating blade, you would ask the question “What can go wrong?”. The operator’s sleeve could get caught by the rotating blade. What are the consequences? His arm or wrist could be amputated. How could it happen? There are no machine guard to prevent such accident. What are other contributing factors? The operator may be fatigued due to long working hours. He may be careless and not paying attention to the blade. Or he may be distracted by talking to his fellow employees while working. How likely is it to happen? Without machine guards or other forms of engineering control, such accident is likely to happen sooner rather than later.

You can apply the same job hazard analysis approach to your environmental program. Let’s call it environmental hazard analysis. Here are a couple of examples:

Example 1: You walk through the plant and you notice some severe signs of corrosion at the base of one of your aboveground storage tanks where you store some pretty hazardous chemicals.  You ask the five questions:

What can go wrong? The structural integrity of the tank can fail.
What are the consequences? The tank could rupture and cause a massive spill of hazardous chemicals.
How could it happen? The tank could fail if no action is taken to address the corrosion of the tank.
What are other contributing factors? Strong wind, minor earthquake or any external forces on the tank could contribute to its structural failure.
How likely is it to happen? It is likely to happen if nothing is done.

Example 2: You are reviewing your plant’s Spill Prevention Control and Countermeasures (SPCC) plan and notice that there is no record of any inspection being carried out even though the plan calls for weekly inspections. You ask the five questions:

What can go wrong? The SPCC plan is not being implemented as planned.
What are the consequences? Spills could have occurred without anyone noticing it. An EPA inspector may issue a citation against your plant for failure to implement it.
How could it happen? The inspection team was not made aware of the weekly inspection requirement.
What are other contributing factors? The people responsible for implementing the plan were not involved in its development. There is a lack of ownership. There is a failure of communication.
How likely is it to happen? The failure to implement the plan is likely to happen if employees are not properly trained and involved in the plan.

Example 3: You notice that there are drums of hazardous waste in your central storage area that do not have the proper labels on them. The ones with labels do not have accumulation start dates. You ask the five questions.

What can go wrong? You can exceed your maximum storage time limit without knowing about it.
What are the consequences? You could be fined for operating a hazardous waste facility without a permit if an inspector finds out.
How could it happen? The operator had not been told about the labeling requirements.
What are other contributing factors? There is no one individual responsible for making sure the label is on the container and it is properly filled out. The weekly inspection has not been carried out or it has not been done properly.
How likely is it to happen? It is very likely to happen.

This simple environmental hazard analysis can help you identify small problem before it festers into a much larger and more costly one. Once you have determined that the problem is likely to happen, you need to take immediate steps to stop it. It is like doing an internal audit. There is no point in doing an audit unless you have the commitment and resources to fix the problems you uncover.

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EPA’s New Greenhouse Gas Reporting Rule

The final rule was signed by the Administrator on September 22, 2009. On October 30, 2009, the  final rule was published in the Federal Register ( under Docket ID No. EPA-HQ-OAR-2008-0508-2278.  The rule went into effect December 29, 2009.

Under this new rule,  suppliers of fossil fuels or industrial greenhouse gases, manufacturers of vehicles and engines, and facilities that emit 25,000 metric tons or more per year of GHG emissions are required to submit annual reports to EPA. The gases covered by the proposed rule are carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFC), perfluorocarbons (PFC), sulfur hexafluoride (SF6), and other fluorinated gases including nitrogen trifluoride (NF3) and hydrofluorinated ethers (HFE).

Facilities need to start collect data on January 1, 2010 and the first emission report is due March 31, 2011. There are special provisions in 40 CFR 98 for some companies in 2010.

The complete regulation (all 261 pages of it) can be downloaded here. A much shorter version (press release) is here.