How to Inventory Your Wastes for Environmental Compliance Produced by the Pacific Northwest Pollution Prevention Resource Center 1326 Fifth Ave, Suite 650, Seattle, Washington 98101 phone: 206-223-1151, fax: 206-223-1165 e-mail: [email protected], web: http://www.pprc.org/pprc/ A joint project of the Small Business Assistance Programs in Alaska, Idaho, Oregon and Washington. Funded by a grant from the U.S. Environmental Protection Agency, Region 10. July 1997 This information is available on the internet at http://www.pprc.org/pprc/sbap/sbap.html CHECKLIST As you go through each section a certain action on your part is suggested. These actions are signified by a check mark . These sections are listed below and should be checked off after you have completed the action suggested in that particular section. Once this list is completely checked off you have successfully progressed through the waste inventory process and have gained a better awareness of your waste streams and how those wastes are regulated. You will have the knowledge to begin to eliminate or reduce these waste streams by implementing pollution prevention opportunities. 1. CREATING WASTE INVENTORY LISTS ____ Hazardous/solid waste inventory ____ Air emission sources inventory ____ Water pollution sources inventory 2. UNDERSTANDING HAZARDOUS WASTES ____ Determine if wastes are hazardous, recyclable or landfillable ____ Quantify monthly generation of hazardous wastes ____ Determine hazardous waste generator status ____ Identify requirements for being a hazardous waste generator 3. UNDERSTANDING AIR EMISSION SOURCES ____ Determine if products contain hazardous air pollutants and other air toxics ____ Estimate annual use of hazardous air pollutants ____ Determine air emission source status (major or area source) ____ Identify requirements for using hazardous air pollutants 4. UNDERSTANDING WATER POLLUTION SOURCES ____ Understand responsibilities and requirements for having water pollution sources ACKNOWLEDGEMENTS The PPRC is indebted to many individuals for assistance with this informational guide. Funding was provided by a grant from the U.S. Environmental Protection Agency. The PPRC wishes to thank the following individuals for their willingness to share the information, ideas and suggestions that helped shape the content of this workbook: • Bernard Brady, Washington Department of Ecology • Bob Burmark, Washington Department of Ecology • Scott Lytle, Alaska Department of Environmental Conservation • Doug McRoberts, Idaho Department of Environmental Quality • Terry Obteshka, Oregon Department of Environmental Quality • Rick Volpel, Oregon Department of Environmental Quality DISCLAIMER The Small Business Assistance Programs in Idaho, Oregon and Washington, and the Compliance Assistance Program in Alaska, were created to provide assistance to small businesses concerning the requirements of the Clean Air Act Amendments of 1990. This compliance and pollution prevention informational guide was created for the programs to provide multimedia compliance and pollution prevention assistance, and to aid small business owners with questions concerning environmental issues. This information is not a comprehensive document covering every environmental regulation that could affect a business. It is the responsibility of the owner/operator to stay abreast of changes in environmental regulations that govern his/her industry. TABLE OF CONTENTS Checklist and Introductory Information ........................................................................ 1 1. CREATING WASTE INVENTORY LISTS ............................................................... 3 Hazardous/Solid Waste Inventory ............................................................................. 5 Air Emission Sources Inventory ................................................................................ 6 Water Pollution Sources Inventory ........................................................................... 7 2. UNDERSTANDING HAZARDOUS WASTES .......................................................... 8 Determine if wastes are hazardous or non-hazardous .............................................. 8 Quantify monthly generation of hazardous wastes ................................................... 11 Determine hazardous waste generator status ........................................................... 12 Identify requirements for being a hazardous waste generator ................................. 13 3. UNDERSTANDING AIR EMISSION SOURCES ..................................................... 17 Determine if products contain regulated chemicals ................................................. 17 Estimate annual use of regulated chemicals .............................................................. 19 Determine air emission source status ........................................................................ 23 Identify requirements for using regulated chemicals ............................................... 24 4. UNDERSTANDING WATER POLLUTION SOURCES .......................................... 26 Understand responsibilities and requirements for managing water pollution sources . 26 APPENDIX A: Internet Resources ................................................................................ 28 APPENDIX B: Contacts List .......................................................................................... 30 APPENDIX C: Weekly Facility Inspection List ............................................................. 33 APPENDIX D: List of Hazardous Air Pollutants ........................................................... 34 APPENDIX E: Other Federal and State Regulations .................................................... 35 INTRODUCTION If you own or operate a business in the Pacific Northwest and are concerned with business competitiveness, environmental regulations, waste, and pollution prevention, this online self-help tool is for you. If youre not concerned about these issues and dont think this information can improve the efficiency of your operations; save you money; help you comply with the laws you should already be following; make you eligible to participate in state, county and local public recognition programs, and reduce your liability by improving employee health and safety think again! Using this information and incorporating its concepts into current waste management practices could be one of the most important business planning decisions you make. Stringent environmental regulations increase demands on your business to stay one step ahead of costs related to environmental compliance; pollution prevention techniques can help you meet this challenge. This self-help information guide is divided into four easy-to-follow chapters to help you better identify and calculate the types and quantities of wastes generated and emitted from your shop, understand the environmental regulations associated with these wastes, and identify opportunities to reduce or eliminate the generation of pollution. Refer to the Contacts List or Appendix A: Internet Resources at any time to find resources available to help you understand your environmental issues and pollution prevention opportunities. A checklist is included to guide you through: 1. Creating Waste Inventory Lists 2. Understanding Hazardous Wastes 3. Understanding Air Emission Sources 4. Understanding Water Pollution Sources Lets get started.... 1 CHECKLIST As you go through each section a certain action on your part is suggested. These actions are signified by a check mark . These sections are listed below and should be checked off after you have completed the action suggested in that particular section. Once this list is completely checked off you have successfully progressed through the waste inventory process and have gained a better awareness of your waste streams and how those wastes are regulated. You will have the knowledge to begin to eliminate or reduce these waste steams by implementing pollution prevention opportunities. 1. CREATING WASTE INVENTORY LISTS ____ Hazardous/solid waste inventory ____ Air emission sources inventory ____ Water pollution sources inventory 2. UNDERSTANDING HAZARDOUS WASTES ____ Determine if wastes are hazardous, recyclable or landfillable ____ Quantify monthly generation of hazardous wastes ____ Determine hazardous waste generator status ____ Identify requirements for being a hazardous waste generator 3. UNDERSTANDING AIR EMISSION SOURCES ____ Determine if products contain hazardous air pollutants and other air toxics ____ Estimate annual use of hazardous air pollutants ____ Determine air emission source status (major or area source) ____ Identify requirements for using hazardous air pollutants 4. UNDERSTANDING WATER POLLUTION SOURCES ____ Understand responsibilities and requirements for having water pollution sources 2 CHAPTER 1. CREATING WASTE INVENTORY LISTS Regulated wastes and emissions from manufacturing operations can include liquid and solid hazardous wastes, air emissions, and waste water. Manufacturers also produce non-hazardous solid waste. Figure 1 shows typical wastes from a manufacturing environment. Look around your business and consider how this figure applies to you. Figure 1: Typical Wastes Encountered in Manufacturing • Aerosol cans • Cleaners • Cleanup sorbents (floor dry) • Contaminated antifreeze • Contaminated fuel • Contaminated used oil • Dirty shop towels • Empty chemical containers • Hazardous Air Pollutants • Packaging waste • Paint-related wastes (sludge, strippers, thinners, etc.) • Paint chips and sandblast media • Parts washer sludge/ solvent • Process water • Solvent still sludge • Spent hydraulic oil • Spent processing chemicals and rinsewater • Surface coating materials • Tramp oils • Vehicle maintenance wastes • Volatile organic compound (VOC) air emissions • Waste acids (hydrochloric, nitric, sulfuric, chromic, etc.) • Waste adhesives • Waste batteries/ battery fluids • Waste solvent Creating a list of all of the waste streams at your facility makes good business sense. An inventory of wastes will: • Allow you to distinguish between wastes that are considered hazardous, air emissions or water pollutants and wastes that can be recycled or landfilled. • Help you make changes in your operating practices as regulations change. Since you will know what wastes are considered hazardous and the quantities of these wastes, the impacts of regulations will be easy to identify. • Guide you on controlling costs associated with meeting your environmental responsibilities. Develop your own inventory list of hazardous waste streams, air emission sources and water wastes for the processes in your facility. Refer to Figure 1 for lists of common manufacturing wastes to help guide you in identifying the different waste streams your processes generate. Next, make copies of the worksheets provided below. Fill out the worksheets to inventory your hazardous and solid wastes, air emissions and water pollution sources. Each worksheet 3 has different instructions, so be sure you record hazardous and solid wastes on the Hazardous/Solid Waste Inventory worksheet; record air emission sources on the Air Emission Sources Inventory worksheet; and record water wastes on the Water Pollution Sources Inventory worksheet. If you use a computer, you may prefer to create your own tables or spreadsheets and enter this information electronically to make calculating and manipulating of the data easier. Obtain a MSDS for Each Waste on Your Inventory Lists All businesses are required by the Occupational Safety and Health Administrations Hazard Communication (Worker-Right-to-Know) rule to maintain an up-to-date collection of Material Safety Data Sheets (MSDSs) for all products used onsite that may affect employee safety or health. You should already be maintaining a full set of relevant MSDSs in a file that is accessible to all employees at your business. The MSDSs will be used to complete the steps in this workbook. You will need to have a copy of the MSDS for each product that is part of a waste you list on the inventory worksheets. If your file is missing a specific MSDS, the best place to obtain a new one is from the product vendor. Vendors are required by law to generate MSDSs for their products and provide copies on demand to customers. If you are not able to get a MSDS you need from a vendor, other possible sources are specialized libraries or the Internet. Librarians at your states or countys environmental agency or at a local college/university often will have MSDS databases. Check the local government section in your telephone book to find out if an environmental or chemistry library is available to you in a government agency or college. There are also several MSDS databases on the Internet (see to Appendix A: Internet Resources). When you have completed each inventory list, check off these actions on the Checklist on page 2 and go on to the next action. If you have questions or need help with your waste inventories, see Appendix B: Contacts List. 4 HAZARDOUS/SOLID WASTE INVENTORY Step 1: Record all of the possible hazardous wastes and all possible solid wastes you identify in your facility under the Waste column. Step 2: Find the MSDS or product data sheet for each recorded waste (check the MSDS column when you have found this sheet). Note: MSDSs are only one tool for waste determination. Other methods, like lab analysis or knowledge of process can be used as tools for waste determination. Step 3: For now, leave the Determined To Be... and Total Pounds/Month columns blank. You will complete these sections when you work through Chapter 2: Understanding Hazardous Wastes. Step 4: When all of your potential hazardous wastes are written down, go to your copy of the Air Emission Sources Inventory worksheet and follow the instructions. INVENTORY OF POSSIBLE HAZARDOUS AND SOLID WASTES Wa s t e MSDS De t e r mi n e d t o b e : Hazar dous To t a l Po u n d s o f H a z a r d o u s Wa s t e Pe r M o n t h 5 Non- hazar dous To t a l Po u n d s / Mo n t h AIR EMISSION SOURCES INVENTORY Step 1: Record all of the possible air emission sources you identify in your facility under the Emission Source column. Step 2: Find the MSDS or product data sheet for each recorded emission source (check the MSDS column when you have found this sheet). Step 3: For now, leave the Determined To Be... and Total Annual Tons column blank. You will complete these sections when you work through Chapter 3: Understanding Air Emission Sources. Step 4: When you have recorded all of your air emission sources, go to your copy of the Water Pollution Sources Inventory worksheet and follow the instructions. INVENTORY OF POSSIBLE AIR EMISSION SOURCES De t e r mi n e d t o b e : Emi s s i o n So u r c e MSDS 189 HAPs Hal ogenat ed S o l ve n t Total Tons of All Regulated Chemicals Per Year 6 TRI NonHazar dous To t a l An nu a l To n s WATER POLLUTION SOURCES INVENTORY Step 1: Record all of the possible water pollution sources you identify in your facility under the Water Pollution Source column. For now, leave the Water Test and Determined to Meet Sewer Discharge Limits blank. You will complete these sections when you work through Chapter 4: Understanding Water Pollution Sources. You are now ready to move on to Chapter 2: Understanding Hazardous Wastes to begin the hazardous waste determination process. INVENTORY OF POSSIBLE WATER POLLUTION SOURCES Wa t e r Po l l u t i o n So u r c e D i s c h a r g e wa s Te s t e d De t e r mi n e d t o Me e t S ewe r D i s c h a r g e L i m i t s ( Ye s / No ) ( Ye s / No ) 7 CHAPTER 2. UNDERSTANDING HAZARDOUS WASTES This section will help you: • Determine if the wastes you identified in your Hazardous/Solid Waste Inventory worksheet are hazardous; • Calculate the pounds of hazardous waste generated on a monthly basis; • Determine your generator status; and • Understand some of the basic requirements for your generator status. You will need your copy of the Hazardous/Solid Waste Inventory worksheet with accompanying MSDSs to proceed with the determination process. DETERMINE IF WASTES ARE HAZARDOUS, RECYCLABLE OR SOLID WASTE There are two methods of determining whether wastes are hazardous. These methods are: 1. Knowledge of Process This method allows business owners to use knowledge of the wastes generated from their processes in deciding whether they have a listed waste, if further waste analysis should be conducted, or, if lab analysis is needed, what type of analysis should be used. 2. Waste Analysis This method allows the business owner to use available raw material data to determine whether the waste stream should be further analyzed in a laboratory. By conducting a waste analysis, you can determine whether wastes have hazardous characteristics. a. Characteristic Hazardous Wastes These are wastes that have certain characteristics (ignitable, reactive, corrosive and/or toxic) that distinguish them from other solid waste materials. b. Listed Wastes These are wastes, specifically listed in the hazardous waste regulations. F-listed hazardous wastes are generally spent cleaning solvents which contain 10% or more of at least one hazardous chemical. If your cleaning products contain any of these chemicals (concentrations of 10% or more) they are automatically considered hazardous waste when disposed. 8 Use MSDS to Help Make Hazardous Waste Determination You can use each products MSDS to help determine if your waste streams meet any of the hazardous waste criteria described below. This section will explore how to apply the information contained in a MSDS to determine if that product meets the criteria for a Characteristic Waste or an F-Listed Waste. Note: MSDSs are used as a screening tool to determine whether each raw material possesses hazardous characteristics. You should apply the waste analysis method to determine unequivocally whether a waste is hazardous. First, take your Hazardous/Solid Waste Inventory worksheet and the MSDSs you have for each of the products which are found in the waste. Read through the steps (below and on the following pages) to determine if a waste is hazardous. If you determine that the waste can be considered hazardous, check that column on your inventory worksheet for the particular waste. If you determine that the waste does not meet any of the hazardous waste criteria, check the Non-hazardous column. Step 1. Determine if Waste Meets Criteria of Characteristic Wastes 1a. Refer to Section IV of the MSDS, usually called Fire and Explosion Data, to find out what the flash point is for this product. If it meets the definition of ignitable, below, the waste has a hazardous characteristic. Ignitable Wastes Common in Industry • wash solvents • methyl ethyl ketone • solvent-based coatings Ignitable Any liquid waste that has a flash point below 140° F (60° C). Any non-liquid capable of spontaneous combustion under normal conditions. An ignitable compressed gas or oxidizer. 1b. Refer to Section III of the MSDS, usually called Physical Data, to find out what the pH level is for this product. If it meets the definition of corrosive, below, then the waste has a hazardous characteristic. Corrosive Wastes Common in Industry • acids • waste battery acid • highly alkaline cleaners Corrosive An aqueous (water-based) material with a pH less than 2.0 or greater than 12.5. 9 1c. Refer to Section VI of the MSDS, usually called Reactivity Data, to find out if this product is stable under all circumstances. If it is unstable or reacts (see definition below) with certain other materials, the waste has a hazardous characteristic. Reactive Unstable materials that react violently without detonating. React violently with water or form an explosive gas, vapor or fume when mixed with water. Contain cyanide or sulfide and generate toxic gas vapors/fumes at a pH between 2 and 12.5. Reactive Wastes Common in Industry • waste bleaches and oxidizers 1d. Refer to Section II of the MSDS, usually called Hazardous Ingredients, and find out if this product contains constituents that would cause the waste to be toxic. You can also have a laboratory conduct a Toxicity Characteristic Leaching Procedure (TCLP) test. If the waste contains hazardous ingredients in certain concentrations, it has a hazardous characteristic. Toxic Contains specific constituents above threshold levels. Typically determined using a TCLP test. Refer to Appendix B: Contacts List to find out who to call to locate a testing facility in your area. This test will determine the amount of toxic materials in the waste stream. Toxic Wastes Common in Industry • process waste water • clean-up solvents • inks, surface coating materials • corrosive cleaners If you need help determining if a waste meets the criteria of characteristic wastes, refer to Appendix B: Contacts List to find out who to call in your area. Step 2. Determine if the Waste Meets the Criteria for F-listed Wastes F-Listed wastes, which are specifically listed in the hazardous waste regulations, are generally spent cleaning solvents that contain 10% or more of at least one hazardous chemical. If your cleaning products contain any of these chemicals (concentrations of 10% or more) they are automatically considered hazardous waste when disposed. Refer to Section II of the MSDS, usually called Hazardous Ingredients, and compare the chemicals found in your product with the list of F-listed chemicals on the following page. If you find one of the chemicals match with the list and is in concentration 10% or more, then this waste has a hazardous characteristic. 10 F-Listed Chemicals Common in Industry acetone cresols and cresylic acid benzene n-butyl alcohol carbon tetrachloride 2-nitropropane carbon disulphide ortho-dichlorobenzene chlorinated fluorocarbons pyridine chorobenzene tetrachloroethylene cyclohexanone toluene 2-ethosyethanol trichloroethylene ethyl ether 1,1,1-trichloroethane isobutanol 1,1,2-trichloroethane methanol 1,1,2-trichloro-1,2,2-trifluoroethane methylene chloride trichlorofluoromethane methyl ethyl ketone (MEK) xylene methyl isobutyl ketone (MIBK) ethyl acetate ethyl benzene nitrobenzene Note: Any still bottoms generated from the distillation or recycling of these solvents must be managed as a hazardous waste. If you need help determining if a waste meets the criteria of F-listed wastes, refer to Appendix B: Contacts List to find out who to call in your area. Step 3. Have a Laboratory Conduct a Toxicity Test on the Waste Stream It is important to understand that some of your waste streams may have been contaminated by several other products. For example, you may have used oil that alone does not have characteristics of a hazardous waste. But if the oil comes in contact with a solvent, that oil may now have a hazardous characteristic. One fail-safe way to determine if a waste is hazardous is to have a laboratory perform a test on the waste stream. If the test shows that toxic substances found in the waste are above certain thresholds, the waste is considered hazardous. Refer to Appendix B: Contacts List or your local telephone directory to locate a testing laboratory in your area. When you have determined if wastes are hazardous, recyclable or landfillable, check off this action on the Checklist on page 2 and go on to the next action. QUANTIFY MONTHLY GENERATION OF HAZARDOUS WASTES Now that you have determined if your wastes are hazardous, you can calculate how many pounds of each waste you generate in one month. This is necessary because your regulatory 11 requirements depend on the total amount of hazardous waste generation in a one-month period. There are several ways to calculate the total monthly generation of a hazardous waste: Method 1 Determine the density (pounds per gallon) of each waste and multiply that by the actual number of gallons of that waste you generate in one month. The density of your waste can be estimated by referring to the MSDS for the product that makes up the waste. Some MSDSs will give you the actual weight of the product per gallon. Other MSDSs will only give you a specific gravity for the product. If your MSDS uses specific gravity, multiply that number by 8.34 (specific gravity x 8.34) to convert to pounds per gallon. Use this weight to calculate your monthly generation. Example: You generate 20 gallons of wash solvent in one month and solvent has a density of 7 lbs./gal. 20 gal. x 7 lbs./gal. = 140 lbs. Method 2 If you have access to a scale, weigh your hazardous waste storage container. This weight is the tare weight. After one month of filling this waste container, weigh it. Subtract the tare weight from this new weight and this will give you an approximate weight in pounds for one month of generation of that particular waste. Example: You have a waste sludge container with a tare weight of 1 lb. and at the end of the month you weigh the container at 50 lbs. 50 lbs. - 1 lb. = 49 lbs. Note: Whether you use Method 1 or Method 2, be sure to record your calculated weight for each hazardous waste stream on your Hazardous/Solid Waste Inventory worksheet and then total all of the hazardous wastes together. When you have quantified your monthly generation of hazardous wastes, check off this action on the Checklist and go on to the next action. DETERMINE HAZARDOUS WASTE GENERATOR STATUS Hazardous Waste: ___________ lbs. per month Enter the total quantity in pounds (lbs.) you calculated from your Hazardous/Solid Waste Inventory worksheet in the above space. Use this number to determine what size hazardous waste generator you are. • Conditionally Exempt Generator (CEG). (The State of Washington refers to this as Small Quantity Generator [SQG]) 1) A company that generates less than 220 lbs. (typically 20-25 12 gallons) of total hazardous waste, or less than 2.2 pounds of acutely hazardous waste* and/or waste that is extremely hazardous due to toxicity in a single calendar month, 2) and the company never accumulates more than 2,200 pounds of hazardous waste or 2.2 pounds of acutely hazardous waste* and/or waste that is extremely hazardous due to toxicity at any time. • Small Quantity Generator (SQG). (The State of Washington refers to this as Medium Quantity Generator [MQG]) 1) A company that generates more than 220 lbs., and less than 2,200 lbs. of hazardous waste per month, and less than 2.2 pounds of acutely hazardous waste in a single calendar month, 2) and the company never accumulates more than 2,200 pounds of dangerous waste or 2.2 pounds of acutely hazardous waste at any time. • Large Quantity Generator (LQG) A company that generates more than 2,200 lbs. of hazardous waste in a single calendar month. As discussed on the following page in Identify Requirements for Being a Hazardous Waste Generator, generators who have the smallest status have the fewest requirements. If you find you are a SQG (MQG in Washington) or LQG, you will want to reduce your monthly generation of waste so you can enjoy the less burdensome requirements of a small quantity generator. This can be accomplished by reviewing and implementing the best management practices and pollution prevention opportunities. If you have questions about your generator status, refer to Appendix B: Contacts List to find out who to call in your area. When you have determined your hazardous waste generator status, check off this action on the Checklist on page 2 and go on to the next action. IDENTIFY REQUIREMENTS FOR BEING A HAZARDOUS WASTE GENERATOR Generator Classification: _______________ Write in your generator classification (CEG [SQG in the State of Washington], SQG [MQG in the State of Washington] or LQG) in the space above and follow the appropriate chart (on the following pages) to identify some of your hazardous waste requirements and recommendations. If you have questions about your your requirements for being a waste generator, refer to Appendix B: Contacts List to find out who to call in your area. When you have identified the requirements for being a hazardous waste generator, check off this action on the Checklist on page 2 and go on to Chapter 3: Understanding Air Emission Sources. ____________________________________ *Acutely hazardous waste is generally more dangerous and/or more toxic than other listed wastes. Acutely hazardous wastes are listed as P-listed wastes. (Refer to Appendix B: Contact List to get more information on P-listed wastes. 13 CONDITIONALLY EXEMPT GENERATOR (CALLED SMALL QUANTITY GENERATOR IN WASHINGTON STATE) Issue Required (Yes/No) How to Comply Determine if solid wastes are designated as dangerous waste Yes Complete Chapter 2 of this workbook. Obtain an EPA/State Generator Identification Number No The state recommends that CEGs (called SQGs in the State of Washington) obtain an Identification Number. Manage waste in a way that does not pose a potential threat to human health/environment Yes Send waste to a permitted facility, legitimate recycler or to sewer agency with permission. Do not dump to drains, dumpsters or sewer without checking with the local authorities. Manifest wastes when shipping hazardous wastes off site No May be required by hazardous waste hauler. Recordkeeping No Annual reporting No If you obtained an Identification Number, you are required to submit an annual report by March 1 for the previous calendar year. Label containers/drums Yes • Department of Transportation labeling generally required. • Health hazard labeling strongly recommended. Prepare Emergency Response Plans No Train employees on proper waste handling and emergency procedures No Inspect on a schedule all monitoring equipment, safety and emergency equipment, structural soundness of drums/containers No 14 SMALL QUANTITY GENERATOR (CALLED MEDIUM QUANTITY GENERATOR IN WASHINGTON STATE) Issue Required Yes/No How to Comply Determine if solid wastes are designated as dangerous waste Yes Complete Chapter 2 of this workbook. Obtain an EPA/State Generator Identification Number Yes Notify your state agency (see Appendix B for telephone number) to obtain Identification Number. Manage waste in a way that does not pose a potential threat to human health/environment Yes Send waste to a permitted facility, legitimate recycler or to sewer agency with permission. Do not dump to sewer without checking with the local authorities. Manifest wastes when shipping hazardous wastes off site Yes Use the Uniform Hazardous Waste Manifest Form when shipping hazardous wastes. Waste must be disposed of within 180 days of accumulation, provided amount is less than 2,200 pounds. Recordkeeping Yes Keep manifests and annual reports onsite for at least 5 years. Annual reporting Yes Complete and submit a Hazardous Waste Annual Report by March 1 for the previous calendar year. Label containers/drums Yes Clearly mark each container of waste with a hazardous waste label that includes the accumulation start date and the type of waste and waste codes. Prepare Emergency Response Plans Yes Post the name and telephone number of the emergency response coordinator, location of fire extinguishers, spill control materials and fire alarms, and telephone number of the fire department. Train employees on proper waste handling and emergency procedures Yes Ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures relevant to their responsibilities. Inspect on a schedule all monitoring equipment, safety and emergency equipment, structural soundness of drums/containers Yes Complete the Weekly Facility Inspection Checklist. Make copies of the checklist, which is provided in Appendix C. 15 LARGE QUANTITY GENERATOR Issue Required Yes/No How to Comply Determine if solid wastes are designated as dangerous waste Yes Complete Chapter 2 of this workbook. Obtain an EPA/State Generator Identification Number Yes Notify your state agency (see Appendix B for telephone number) to obtain Identification Number. Manage waste in a way that does not pose a potential threat to human health/environment Yes Send waste to a permitted facility, legitimate recycler or to sewer agency with permission. Do not dump to sewer without checking with the local authorities. Manifest wastes when shipping hazardous wastes off site Yes Use the Uniform Hazardous Waste Manifest Form when shipping hazardous wastes. Waste must be disposed of within 90 days of accumulation. Recordkeeping Yes Keep manifests and annual reports onsite for at least 5 years. Annual reporting Yes Complete and submit a Hazardous Waste Annual Report by March 1 for the previous calendar year. Label containers/drums Yes Clearly mark each container of waste with a hazardous waste label that includes the accumulation start date and the type of waste and waste codes. Prepare Emergency Response Plans Yes Formal Plan Required. Train employees on proper waste handling and emergency procedures Yes Ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures relevant to their responsibilities. Inspect on a schedule all monitoring equipment, safety and emergency equipment, structural soundness of drums/containers Yes Complete the Weekly Facility Inspection Checklist. Make copies of the checklist, which is provided in Appendix C. 16 CHAPTER 3. UNDERSTANDING AIR EMISSION SOURCES This section of the workbook will help you: • Determine if the air emission sources you identified on your Air Emission Sources Inventory worksheet contain regulated chemicals; • Perform simple calculations to estimate your annual use of these chemicals; • Determine your status as an air emitter based on the quantity of chemicals used; and • Understand some of the basic requirements for your source status and air pollutant emitting equipment. You will need your copy of the Air Emission Sources Inventory worksheet with accompanying MSDSs to proceed with the determination process. DETERMINE IF PRODUCTS CONTAIN REGULATED CHEMICALS This section will help you determine whether your process materials contain chemicals on one of three lists: 1) chemicals regulated as Hazardous Air Pollutants (HAPs), 2) very toxic chemicals used as cleaning solvents, and/or 3) chemicals reportable under the Toxics Release Inventory (TRI) section of the Emergency Planning and Community Right-to-Know Act (EPCRA). Many chemicals are on more than one of the three lists. Using the MSDS you have for each air emission source you identified on your Air Emission Source Inventory worksheet, complete the following steps: Step 1: Go to Section II of the MSDS, usually called Hazardous Ingredients, which lists all of the chemicals that make up that particular product. Step 2: As you read each chemical off the MSDS sheet, refer to Table 5 on the next page to see if that chemical is listed. Table 5 is a selection, taken from the 189 Hazardous Air Pollutants (HAPs) list, of chemicals commonly used by industry. Refer to Appendix D: Hazardous Air Pollutants for the full list. Step 3: If you find a match between chemicals on the MSDS with a chemical in Table 5 or in the Appendix D list, set that MSDS aside (which youll use later when calculating your total emissions). 17 Step 4: If no chemical match is found, continue comparing the chemicals on the MSDS with the chemicals found in the list of chemicals in Table 6 on the following page and Table 7 on page 19. Step 5: Check the appropriate column on your Air Emission Sources Inventory worksheet when you determine the nature of the chemicals you use (189 HAPs, Halogenated Cleaning Solvent, TRI or Not an Emission Source). If you are unsure whether a product contains hazardous air pollutants, refer to Appendix B: Contacts List to find out who to call in your area. 189 HAPs The chemicals listed in Table 5, which are commonly used by many industries, are listed as HAPs. See Appendix D for a complete list of the 189 HAPs. Table 5: Chemicals on the List of 189 HAPs that are Commonly Used in Industry Benzene Cadmium compounds Carbon tetrachloride Chromium compounds Cumene Dibutylphthalate Diethanolamine Ethyl benzene Formaldahyde Glycol ethers Hexane Hydrochloric acid Isophorone Lead compounds Methanol Methyl ethyl ketone Methylene Chloride Tetrachloroethylene Polycyclic organic matter Propylene oxide Toluene 2,4-toluene diisocyanate 1,1,1-trichloroethane Vinyl chloride Halogenated Cleaning Solvents Some of the cleaning liquids in parts washers are considered very toxic and are heavily regulated. If you use a parts washer, refer to the cleaning liquids MSDS to determine if the liquid contains any of the chemicals listed in Table 6 (below). If you find that the cleaning product you are using does contain any of the chemicals in Table 6, refer to Appendix B to find out who to call in your state. Table 6: Chemicals on the List of HAPs Commonly Used in Cleaning Equipment Carbon tetrachloride Chloroform Methylene chloride Perchloroethylene Trichloroethylene 1,1,1-trichloroethane 18 Toxics Release Inventory Chemicals used by industry that are listed in the Toxics Release Inventory (TRI) are included in Table 7 on the following page. Table 7: Chemicals on the TRI that are Commonly Used in Industry Ammonia Barium Cadmium Chromium Copper Cumene Cyclohexane Ethylbenzene Ethylene glycol Ethylene oxide Formaldehyde Freon 113 Hydrochloric acid Hydroquinone Lead Methanol Methyl ethyl ketone Methyl isobutyl ketone Methylene chloride Phosphoric acid Silver Sulfuric acid Tetrachloroethylene Toluene Trichloroethylene 1,1,1-trichloroethane Xylene Note: Table 7 is not a complete listing of all chemiccals reportable under EPCRA. The full list includes more than 600 chemicals. When you have determined if products contain hazardous air pollutants and other air toxics, check off this action on the Checklist on page 2 and go on to the next action. ESTIMATE ANNUAL USE OF REGULATED CHEMICALS You should now have a group of MSDSs for products that you determined to contain regulated chemicals. Write down the products name and the chemicals that are in that product in the appropriate spaces of the tables provided on page 22 (make extra copies of this page, if necessary). Then, follow steps 1-5 to determine how many chemicals, and in what quantities, you use annually. The following steps will help you perform a mass-balance calculation of your annual emissions. This method is used to estimate the amount of chemical in your products, and assumes 100 percent of the chemical is emitted. Step 1: Calculate Total Annual Usage of Regulated Chemicals Using invoices, add up the total gallons purchased of a product in one year. Multiply this total by the density (lbs./gal.) of the product and record this figure in the Total Pounds of Product column in the table. (The lbs./gal. is usually shown in the Physical/Chemical Data section of the MSDS.) If specific gravity is given instead of actual lbs./gal., multiply the specific gravity by 8.34 to get lbs./gal. Multiply this figure by total gallons purchased, and record the total in the Total Pounds of Product column. 19 For example, say you purchased 2,000 gallons of paint, which weighs 9.17 lbs./gal., or has a specific gravity of 1.1. (To convert specific gravity to lbs./gal., multiply 1.1 by 8.34, which equals 9.17.) Next, multiply 2,000 gallons by 9.17 to calculate the total pounds of the product. Example: 2,000 gallons x 9.17 lbs./gallon = 18,340 lbs. of product used Enter 18,340 in the Total Pounds of Product column. Step 2: Calculate the Percentage of Chemical in Product Section II of the MSDS lists the percentage of each chemical in the product. Often, this is called Weight Percent. Find this number and convert it to a decimal (multiply by 0.01), and record the new figure in the Weight Percent column in the table. If weight percent is provided in a decimal, simply record that figure in the Weight Percent column. For example, if Chemical X in the paint product you bought has a weight percent of 40, multiply 40 by 0.01 to calculate the weight percent. Example: 40 x .01 = 0.4 Enter 0.4 in the Weight Percent column. Step 3: Calculate the Total Pounds of Chemical Multiply the number in the Weight Percent column with the quantity in Total Pounds of Product column, and record the total in the Total Pounds of Chemical column in the table. Put a check in Column A if you know this chemical is found in other products. This will help remind you to add up the totals for each chemical from other worksheets. For example, for Chemical X you would multiply the weight percent (0.4) by the total pounds of the chemical (18,340) to determine the total pounds of the chemical. Example: 0.4 x 18,340 lbs. = 7,336 lbs. emission of chemical constituent Enter 7,336 in the Total Pounds of Chemical column. Step 4: Calculate the Total Tons of Chemicals You Use per Year Add the totals in the Total Pounds of Chemical column for each product, and divide by 2,000. This number is your total tons per year for all chemicals used in your process materials. Next, add the total pounds of each chemical (refer to Column A to identify chemicals found in multiple products) and divide by 2,000. This number is your total tons per year for each particular chemical. For example, if Chemical X is found only in one product (i.e. Column A is not checked), you would divide the total pounds of the chemical (7,336) by 2,000 to determine the total tons of Chemical X you use in one year. Example: 7,336/2,000 = 3.67 tons 20 Step 5: Calculate Grand Total Add the Total Pounds/Year figures from each worksheet to determine the total pounds of all chemicals you use. Divide this figure by 2,000 to determine Total Tons/Year. Enter this figure in the Grand Total Tons of Chemicals space below the tables and in the Total Tons of All Regulated Chemcials Per Year space on the Air Emission Sources Inventory worksheet. When you have estimated your annual use of hazardous air pollutants, check off this action on the Checklist on page 2 and go on to the next action. 21 Product Name ________________________________________ Chemical Name Ex amp l e: Ch emi c al " X" Total Pounds of Product Weight Percent Total Pounds of Chemical 18,340 l b s . 0.4 7,336 l b s . Column A Total Pounds/Year Total Tons/Year Product Name ________________________________________ Chemical Name Total Pounds of Product Weight Percent Total Pounds of Chemical Column A Total Pounds/Year Total Tons/Year Product Name ________________________________________ Chemical Name Total Pounds of Product Weight Percent Total Pounds of Chemical Total Pounds/Year Total Tons/Year Grand Total Tons of Chemicals: ___________________________________ 22 Column A DETERMINE AIR EMISSION SOURCE STATUS Air Emissions: ___________ tons per year Enter the total estimated tons of regulated chemicals that you calculated on the previous pages in the above space. Use this number to figure out what type of air emission source your business is classified as. The total quantity typically reflects the total amount of HAPs emitted annually. Thats because many HAPs are also found on the Halogenated Cleaning Solvents and TRI lists. Major Source Your business is considered a major source of air emissions if your processes emit or have the potential to emit*: • 10 tons (20,000 lbs.) or more of any one chemical on the list of 189 HAPs, or • 25 tons (50,000 lbs.) or more of any combination of chemicals on the list of 189 HAPs, or • More than 100 tons (150,000 lbs.) of all Volatile Organic Compound (VOC) emissions. Check with your local or state air pollution control agency to determine what additional chemicals, other than those you inventoried, are considered VOCs. Most small businesses, however, do not use enough chemicals to exceed this threshold. See Appendix B: Contacts List. Area Source An area source of air emissions are facilities that emit regulated air pollutants below the threshold levels of major sources. As is discussed on the following page under Identify Requirements for Using Regulated Chemicals, attaining area source status or using equipment and process materials that contain non-regulated materials have the fewest requirements. If you find you are a major source and are using regulated chemicals, you will want to reduce your annual usage and find alternative process materials. By achieving these reductions you can enjoy the less burdensome requirements. This can be accomplished by reviewing and implementing best management practices and pollution prevention opportunities. * Potential to emit is the maximum amount of air pollutant your facility can emit if 1. each process unit is operated at 100 percent of its physical and operational design capacity; 2. materials that emit the most air pollution are used 100 percent of the time; 3. all of the equipment is operating 24 hours per day, 365 days per year; and 4. no pollution control equipment is used. 23 Following is just one of these opportunities, which can eliminate or reduce the use of regulated chemicals. Use less toxic cleaners that have low air emissions Work with your vendor to find less toxic substitutes to your solvent cleaners (surface preparation, parts washers, equipment cleaning). When you begin testing alternatives, follow manufacturer instructions carefully because the new product may need a different working approach than your old cleaning solution required. When you have determined your air emission source status, check off this action on the Checklist on page 2 and go on to the next action. For help determining your air emission source status, refer to Appendix B: Contacts List. The next action item in this workbook explores some of the general requirements associated with your classification as a source of air emissions. Again, this workbook does not include information on local regulations. Local authorities such as solid waste districts, county health departments, air pollution control agencies, and sewage treatment districts may have additional environmental requirements. Refer to you telephone directory to find out who to call. IDENTIFY REQUIREMENTS FOR USING REGULATED CHEMICALS There are two ways your facility can be regulated for using hazardous air pollutants in your processes. One is to regulate (usually by a permit or registration process) the entire facility because of the chemicals it uses; and a second is by regulating specific equipment and processes (i.e. using halogenated solvents in parts washers). This section points out several of these major regulations that affect industrial sectors. However, if your facility is in an area with a local air pollution control agency (such as the Puget Sound area), you may have additional requirements and should contact the local agency to find out. (See Appendix B: Contacts List for local air authority contacts.) HAPs Major Sources As a major source of air emissions, your business faces a much more stringent and complicated set of rules. The permit and/or registration systems and the National Emission Standards for Hazardous Air Pollutants (NESHAP) for industrial sectors and processes, which are associated with being a major source, are difficult to cover in the context of this informational 24 guide. If you have determined your status is that of a major source, refer to Appendix B: Contacts List to find out who to call in your state for more information. Area Sources Each state and local air quality authority may have rules and standards placed on area sources. Over the next several years, the EPA is expected to tighten the air quality rules to include non-major sources of air pollution. By understanding your air emission sources and quantities of regulated chemicals that you use, you will immediately know how you fit into the regulatory framework as rules are developed. Any business located in a designated ozone non-attainment area should refer to Appendix B: Contacts List because special standards may apply. Note: In Oregon, businesses emitting more than 10 tons of non-hazardous VOC emissions are required to operate under a state air permit. Other states and local air authorities also may have a registration system for businesses that have VOC emissions. Halogenated Solvent Cleaning All facilities that operate any size solvent cleaning equipment (solvent immersion or stand-up parts washer) using any of the following solvents methylene chloride, tetrachloroethylene (also known as perchloroethylene), trichloroethylene, 1,1,1 trichloroethane, carbon tetrachloride or chloroform are affected by the NESHAP Halogenated Solvent Cleaning regulation. If you use these chemicals in solvent cleaning machinery you have several compliance options (see Figure 2 below). Figure 2: Options for Complying with Cleaning Equipment NESHAP DIP TANK PARTS WASHER (Immersion Batch Cold Cleaning Equipment) (Remote Reservoir Batch Cold Cleaning Equipment) Required Controls Option 1 1. Install a cover. 2. Achieve 1-inch water layer. 3. No work practices required. Required Controls Option 2 1. Install a cover. 2. Maintain a freeboard ratio of 0.75 or greater. 3. Work practices required. 1. Install a cover. 2. Work practices required. Work Practices 1. Store solvent waste in closed containers. 2. Flush parts in freeboard area. 3. Reduce pooling of solvent on and in parts. 4. Do not fill cleaning equipment above fill line. 5. Clean solvent spills immediately. 6. Store wipe rags in closed containers. 7. Do not agitate solvent to the point of causing splashing. 8. When cover is open, control room drafts. 9. Do not clean absorbent materials. TRI See Appendix E: Other Federal and State Regulations for a discussion on the Emergency Planning and Community Right-to-Know Act (EPCRA). When you have identified the requirements for using hazardous air pollutants, check off this action on the Checklist on page 2 and go on to Chapter 4: Understanding Water Pollution Sources. 25 CHAPTER 4. UNDERSTANDING WATER POLLUTION SOURCES UNDERSTAND RESPONSIBILITIES AND REQUIREMENTS FOR MANAGING WATER POLLUTION SOURCES Wastewater Many industries typically discharge wastewater to a publicly owned treatment works (POTW). It is important for operators to know where the wastewater from their shop is going, and to minimize pollution going down the drain. In addition, POTWs are not equipped to treat all types of industrial wastes (e.g., some solvents can pass through a POTW without being removed or treated). There are three typical sources of water pollution from industrial operations: 1) Process water discharges. Process water often contains metals, oils and greases, acids, suspended solids and many other contaminants. Industrial discharges should meet local, state or federal discharge limits for these contaminants. 2) Coatings or solvents can be a problem if dumped down the drain. Do not dump solvents into any drains, regardless of whether they discharge to a sanitary sewer or a septic system, because such disposal is usually prohibited by state and local regulations. 3) Materials discharged to floor drains or storm sewers. Storm sewers often flow directly into rivers or streams without treatment. Remove any inks, chemicals, oils, etc., before wet rinsing areas that have open floor drains. You can minimize the potential for any unintended releases to the sewer system by putting removable, sealed covers on your floor drains. Take the following steps to determine whether your water wastes meet sewer discharge limits in your area. For each water pollution source identified on your Water Pollution Sources Inventory worksheet, enter yes or no in the column Determined to Meet Sewer Discharge Limits on the worksheet. If unsure, you may need to have a water test done for each water pollution source in question. Step 1: Determine if wastewater is hazardous The one fail-safe way to determine if your wastewater is considered hazardous is to have a laboratory test the wastewater. Refer to your local telephone directory to find a laboratory, or see Appendix B: Contacts List to find out who to call in your area. Testing the wastewater before discharge allows you to see which chemicals, and their concentrations, are found in the wastewater. After you have determined the concentrations of certain chemicals in the wastewater, you can compare those with the limits set by your local sewerage agency (refer to your telephone directory to find out who to call). 26 If the wastewater is determined to meet sewer discharge limits, remember to record yes on your Water Pollution Sources Inventory worksheet. Step 2: Estimate quantity generated Regardless of the waste quantity you generate, your waste water must be treated as a hazardous waste if it does not meet your local sewer agencys discharge limits. In that case, it cannot be discharged to the sewer, storm drains or in any other way that would expose the environment to the wastes. Step 3: Identify requirements A permit may be required depending on the area your business resides in and the discharge limits set at the local level. Consult your local sewerage agency to determine what requirements apply. Stormwater In addition to wastewater discharges, industry should be concerned about stormwater discharges. You can reduce the potential for stormwater contamination at your property by storing raw materials and wastes indoors. If there is no potential for contaminating stormwater on your facilitys grounds, then you are not required to obtain a permit. However, you should apply for a stormwater permit if there is the possibility that stormwater, rainfall, or snow melt water will come in contact with: material handling equipment or activities, raw materials, intermediate products, final products, waste materials, by products or industrial machinery that have the potential of contaminating stormwater. Refer to your telephone directory to find the local agency that handles stormwater permitting. If you have questions about your responsibilities and requirements for having water pollution sources, refer to Appendix B: Contacts List to find out who to call in your state. Once you understand the responsibilities and requirements for having water pollution sources, check off the actions on the Checklist on page 2. Having completed Chapters 1-4, you should now understand your hazardous wastes, air emission sources and water pollution sources. Refer to Appendix E: Other Federal and State Regulations to be sure you understand all of the environmental requirements associated with the wastes you identified. You now have the knowledge to consider eliminating or reducing waste streams by implementing best management practices and pollution prevention opportunitites. 27 APPENDIX A. INTERNET RESOURCES Enviro$en$e Enviro$en$e is a free, public, integrated environmental information system. It is designed to: assist users in finding and implementing common-sense solutions, such as pollution prevention, to environmental problems; facilitate the sharing of technology, procedures and experience across federal agencies, other governmental organizations, manufacturers, suppliers, researchers and others; and encourage the development and demonstration of pollution prevention technologies. Enviro$en$e can link you to most requests for information on the environment and the pollution prevention opportunities and technologies that would benefit your business. http://es.epa.gov Pacific Northwest Pollution Prevention Resource Center Web Site Information on this web site will benefit industry representatives, technical assistance providers, researchers, funders of pollution prevention activities and others. For example, industry representatives and technical assistance providers can use it to obtain general information on cutting-edge approaches to environmental problems, and to identify professionals with technical expertise in specific areas. http://www.pprc.org/pprc Office of Air Quality Planning and Standards - Technology Transfer Network This network provides information and technical support on air pollution control. Its four divisions - Air Quality Management, Emission Standards, Technical Support, and Stationary Source Compliance - provide services to EPA regional offices, state and local agencies, consultants, industry and the general public. These services include clearinghouses, conferences, reports, manuals, newsletters, support centers, workshops, classroom training, self-instructional courses and Technology Transfer Network (TTN). The TTN is one of the most useful bulletin boards to find information on Clean Air Act specifics, and new rules and regulations that may impact your business. These are the rules that regulators browse through, and you should take advantage of acquiring that same knowledge. http://www.epa.gov/ttn U.S. Environmental Protection Agency This Web site hosts information and contacts for promulgated federal regulations, state and local authorities, available publications, and other resources. http://www.epa.gov/ Oregon Department of Environmental Quality Directory This Web site is a directory of contacts in the different media programs -- air quality, water quality, hazardous waste, etc. Once you get to this page, scroll down to the appropriate program you want information on and link directly to that page. http://www.deq.state.or.us:80/ Alaska Compliance Assistance Office This Web site gives contacts for compliance assistance with Alaska's environmental regulations. The Compliance Assistance Office helps businesses, communities, government agencies and the general public to maintain environmental quality and achieve greater compliance with environmental regulations. http://www.state.ak.us/local/akpages/ENV.CONSERV/ Washington Department of Ecology This Web site is dedicated to providing contacts for the different local air authorities. This page lists the contacts by the county that the agency has direct authority over. The Air Quality Business Assistance Program serves many industries that have air quality impacts, and information is available through these air quality authority contacts. http://www.wa.gov/ecology/ EPA Fact Sheets on Regulated Toxic Chemicals This page contains links to EPA fact sheets for every regulated toxic chemical. http://mail.odsnet.com/TRIFacts/ Hazardous Chemical Database This database will allow the user to retrieve information by key-word search for any of 2,000 hazardous chemicals. http://ull.chemistry.uakron.edu/erd/ Material Safety Data Sheet(s) This Web site provides links to many other sites that have MSDS databases and other health and environmental information. http://www.lib.iastate.edu:80/agnic/msds.html Oxford MSDS Database This Web sites home page is an Index of Material Safety Data Sheets in alphabetical order. The user can select the first letter of the particular chemical for which he or she is searching, and then select the appropriate chemical from the list that is presented. http://physchem.ox.ac.uk:80/MSDS/ APPENDIX B. CONTACTS LIST Alaska Department of Environmental Conservation Small Business Compliance Assistance Office Scott Lytle: 907-269-7571 Compliance Assistance Office - Pollution Prevention Division David Wigglesworth: 907-269-7582 Idaho Division of Environmental Quality Small Business Assistance Program Doug McRoberts: 208-373-0497 Pollution Prevention Program North Idaho Regional Office: 208-769-1422 North Central Regional Office: 208-799-4370 Eastern Regional Office: 208-528-2650 Southwest Regional Office: 208-373-0550 South Central Regional Office: 208-736-2190 Southeast Regional Office: 208-236-6160 Oregon Department of Environmental Quality Small Business Assistance Program Terry Obteshka: 503-229-6147 Waste Reduction Assistance Program Northwest Regional Office Kevin Masterson: 503-229-5615 Karen Whisler: 503-229-6191 Renei Nomora: 503-229-5564 Salem Office Bart Collinsworth: 503-378-8240 ext. 253 Dave Rozell: 503-378-8240 ext. 258 Roseburg Office David Livengood: 541-440-3338 ext. 230 Bend Office John MacKeller: 541-388-6146 ext. 229 Pendleton Office Marie Zuroske: 541-278-4622 Washington Department of Ecology Small Business Assistance Program Bernard Brady: 360-407-6803 Leighton Pratt, Small Business Ombudsman: 360-407-7018 Department of Ecology Regional Offices Chelan, Douglas, Kittitas, Klickitat, Okanogan counties - Ecology Central Regional Office 509-575-2490 San Juan County - Ecology Northwest Regional Office 425-649-7000 Adams, Asotin, Columbia, Ferry, Franklin, Garfield, Grant, Lincoln, Pend Oreille, Spokane, Stevens, Walla Walla, Whitman counties - Ecology Eastern Regional Office 509-456-3114 Hazardous Waste and Toxics Reduction Program Northwest Regional Office, Bellevue: 425-649-7000 Southwest Regional Office, Lacey: 360-407-6300 Central Regional Office, Yakima: 509-575-2490 Eastern Regional Office, Spokane: 509-456-2926 Permit Assistance Center This program helps you map out your permit strategy over the phone or in person. Specifically the center can: help orient you to the realm of environmental permitting; advise you on which local, state and federal permits may apply; identify key contacts at government agencies; help you estimate how much time and effort youll spend obtaining permits; and help you avoid potential time, money and regulatory traps. Contact the Permit Assistance Center by: Phone: 360-407-7037 Fax: 360-407-6904 E-mail: [email protected] In person: 300 Desmond Drive S.E., Lacey, Washington Local Air Quality Agencies in Washington King, Kitsap, Pierce, Snohomish counties - Puget Sound Air Pollution Control Agency 206-343-8800 or 1-800-552-3565 Clallam, Grays Harbor, Jefferson, Mason, Pacific, Thurston counties - Olympic Air Pollution Control Authority 360-438-8768 or 1-800-422-5623 Island, Skagit, Whatcom counties - Northwest Air Pollution Authority 360-428-1617 Clark, Cowlitz, Lewis, Skamania, Wahkiakum counties - Southwest Air Pollution Control Authority 360-694-5006, ext. 13 Spokane County - Spokane County Air Pollution Control Authority 509-456-4727 Yakima County - Yakima County Clean Air Authority 509-574-1410 Benton County - Benton County Clean Air Authority 509-943-3396 Regional Resources Pacific Northwest Pollution Prevention Resource Center (PPRC) The PPRC is a non-profit organization that devotes much effort to relationshipbuilding among federal and state governmental agencies, industry representatives, environmental organizations, the academic community and others. Its central contributions are in making high-quality information available to decision-makers to help them identify productive new pathways, identifying research needs by evaluating opportunities for and barriers to the implementation of pollution prevention, and catalyzing projects that address those needs. Contact the PPRC by calling 206-223-1151, or visit its Web site at: http://www.pprc.org/pprc. APPENDIX C. WEEKLY FACILITY INSPECTION CHECKLIST Performing weekly hazardous waste inspections is one of the simplest ways you can protect your facility from a leak or spill, as well as meet new container regulations. If done correctly, your effort will prevent potential releases to the environment before they occur, ensure that wastes are identified properly, and see that wastes are shipped off-site before your accumulation time is up. Make copies of this Checklist for each week in the year and keep them for record. WEEKLY INSPECTION CHECKLIST Inspection for the week of _________ to _________ ACCUMULATION _____ Are all drums and containers marked with a hazardous waste label? _____ Are all drums and containers marked with a risk label, if appropriate? _____ Are all drums marked with the accumulation start date? _____ Are there any drums that are near or have exceeded the 90/180 day timeframe? _____ Are all drums marked with the proper waste code(s)? _____ Are all containers closed? _____ Are all drum labels visible and readable? _____ Are all drums and containers in good condition? _____ Are there 30 inches of aisle space between rows of containers? _____ Are any drums leaking? SUMPS _____ Are sumps clean and free of contamination, spills, leaks and standing water? SAFETY EQUIPMENT _____ Are fire extinguishers charged? _____ Are spill kits stocked? _____ Is the first aid cabinet stocked? _____ Is the emergency shower and eye wash station functioning properly? _____ Are the emergency communication devices operating properly? _____ Is emergency response information posted near all communication devices? SECONDARY CONTAINMENT _____ Is the secondary containment free of cracks or other failures? COMMENTS Describe the actions that you took to correct the deficiencies noted above, and the date the actions were taken ______________________________________________________________________________________________ ______________________________________________________________________________________________ Printed Name _______________________________ Signature ________________________________ Date_______________ Time ______________ APPENDIX D. LIST OF HAZARDOUS AIR POLLUTANTS CAS # 75070 60355 75058 98862 53963 107028 79061 79107 107131 8107051 92671 62533 90040 1332214 71432 92875 98077 100447 92524 117817 542881 75252 106990 156627 105602 133062 63252 75150 56235 463581 120809 133904 57749 7782505 79118 532274 108907 510156 67663 107302 126998 19773 95487 108394 106445 98828 94757 3547044 334883 132649 96128 84742 106467 91941 111444 542756 62737 111422 121697 64675 119904 60117 119937 79447 Chemical Name CAS # 68122 57147 131113 77781 534521 51285 121142 123911 122667 106898 Acetaldehyde Acetamide Acetonitrile Acetophenone 2-Acetylaminofluorene Acrolein Acrylamide Acrylic acid Acrylonitrile Allyl chloride 4-Aminobiphenyl 106887 Aniline 140885 o-Anisidine 100414 Asbestos 51796 Benzene (including from gasoline) 75003 Benzidine 106934 Benzotrichloride 107062 Benzyl chloride Biphenyl Bis (2-ethylhexyl) phthalate (DEHP) 107211 151564 Bis(chloromethyl) ether 75218 Bromoform 96457 1,3-Butadiene 75343 Calcium cyanamide Caprolactam 50000 Captan 76448 Carbaryl 118741 Carbon disulfide 87683 Carbon tetrachloride 77474 Carbonyl sulfide 67721 Catechol 822060 Chloramben 680319 Chlordane 110543 Chlorine 302012 Chloroacetic acid 7647010 2-Chloroacetophenone 7664393 Chlorobenzene 123319 Chlorobenzilate 78591 Chloroform 58899 Chloromethyl methyl ether 108316 Chloroprene 67561 Cresols/Cresylic acid (isomers and 72435 mixture) 74839 0-Cresol 74873 m-Cresol 71556 p-Cresol Cumene 78933 2,4-D, salts and esters 60344 DDE 74884 Diazomethane 108101 Dibenzofurans 624839 1,2-Dibromo-3-chloropropane 80626 Dibutylphthalate 1634044 1,4-Dichlorobenzene(p) 101144 3,3'-Dichlorobenzidene 75092 Dichloroethyl ether 101688 (Bis(2chloroethyl)ether) 101779 1,3-Dichloropropene 91203 Dichlorvos 98953 Diethanolamine 92933 N,N-Diethyl aniline 100027 (N,N-Dimethylaniline) 79469 Diethyl sulfate 684935 3,3-Dimethoxybenzidine 62759 Dimethyl aminoazobenzene 59892 3,3-Dimethylbenzidine 56382 Dimethyl carbamoyl chloride Chemical Name Dimethyl formamide 1,1 Dimethylhydrazine Dimethyl phthalate Dimethyl sulfate 4,6-Dinitro-o-cresol, and salts 2,4-Dinitrophenol 2,4-Dinitrotoluene 1,4-Dioxane (1,4-Diethyleneoxide) 1,2-Diphenylhydrazine Epichlorohydrin (l-Chloro-2,3-epoxypropane) 1,2-Epoxybutane Ethyl acrylate Ethyl benzene Ethyl carbamate (Urethane) Ethyl chloride (Chloroethane) Ethyl enedibromide (Dibromoethane) Ethyl enedichloride (1,2-Dichloroethane) Ethylene glycol Ethyleneimine (Aziridine) Ethylene oxide Ethylene thiourea Ethylidene dichloride (1,1-Dichloroethane) Formaldehyde Heptachlor Hexachlorobenzene Hexachlorobutadiene Hexachlorocyclopentadiene Hexachloroethane Hexamethylene-1,6-diisocyanate Hexamethylphosphoramide Hexane Hydrazine Hydrochloric acid Hydrogen fluoride (Hydrofluoric acid) Hydroquinone Isophorone Lindane (all isomers) Maleic anhydride Methanol Methoxychlor Methyl bromide (Bromomethane) Methyl chloride (Chloromethane) Methyl chloroform (1,1,1-Trichloroethane) Methyl ethyl ketone (2-Butanone) Methyl hydrazine Methyl iodide (Iodomethane) Methyl isobutyl ketone (Hexone) Methyl isocyanate Methyl methacrylate Methyl tert butyl ether 4,4-Methylene bis (2-chloroaniline) Methylene chloride (Dichloromethane) Methylene diphenyl diisocyanate (MDI) 4,4'-Methylenedianiline Naphthalene Nitrobenzene 4-Nitrobiphenyl 4-Nitrophenol 2-Nitropropane N-Nitroso-N-methylurea N-Nitrosodimethylamine N-Nitrosomorpholine Parathion CAS # 82688 87865 108952 106503 75445 7803512 7723140 85449 1336363 1120714 57578 123386 114261 78875 75569 75558 91225 106514 100425 96093 1746016 79345 127184 7550450 108883 95807 584849 95534 8001352 120821 79005 79016 95954 88062 121448 1582098 540841 108054 593602 75014 75354 1330207 95476 108383 106423 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Chemical Name Pentachloronitrobenzene (Quintobenzene) Pentachlorophenol Phenol p-Phenylenediamine Phosgene Phosphine Phosphorus Phthalic anhydride Polychlorinated biphenyls (Aroclors) 1,3-Propane sultone beta-Propiolactone Propionaldehyde Propoxur (Baygon) Propylene dichloride (1,2-Dichloropropane) Propylene oxide 1,2-Propylenimine (2-Methyl aziridine) Quinoline Quinone Styrene Styrene oxide 2,3,7,8-Tetrachlorodibenzo-p-dioxin 1,1,2,2-Tetrachloroethane Tetrachloroethylene (Perchloroethylene) Titanium tetrachloride Toluene 2,4-Toluene diamine 2,4-Toluene diisocyanate o-Toluidine Toxaphene (chlorinated camphene) 1,2,4-Trichlorobenzene 1,1,2-Trichloroethane Trichloroethylene 2,4,5-Trichlorophenol 2,4,6-Trichlorophenol Triethylamine Trifluralin 2,2,4-Trimethylpentane Vinyl acetate Vinyl bromide Vinyl chloride Vinylidene chloride (1,1-Dichloroethylene) Xylenes (isomers and mixture) o-Xylenes m-Xylenes p-Xylenes Antimony compounds Arsenic compounds (inorganic, including arsine) Beryllium compounds Cadmium compounds Chromium compounds Cobalt compounds Coke oven emissions Cyanide compounds Glycol ethers Lead compounds Manganese compounds Mercury compounds Mineral fibers Nickel compounds Polycyclic organic matter Radionuclides (including radon) Selenium compounds APPENDIX E. OTHER FEDERAL AND STATE REGULATIONS Community Right-to-Know If you calculated 10,000 pounds or more annual usage of any of the TRI-listed chemicals or other hazardous substances, you may have a responsibility to report those chemicals. This report is required by July 1 of each year for the chemical(s) used in the previous calendar year. Clean Water Act (CWA) The primary goal of the CWA is to protect, restore and maintain the chemical, physical and biological integrity of the waters of the United States. One interim goal of the act is to return the nations water to conditions deemed fishable and swimmable. All discharges into the waters of the United States, publicly owned treatment works, stormwater discharges, and storm sewers are covered under this act. Direct discharge to any surface water requires a National Pollutant Discharge Elimination System (NPDES) permit. Discharge to a publicly owned treatment works (POTW) does not require a NPDES permit, but will require an industrial user permit which is issued by the local water treatment operator. At this time, no categorical pre-treatment standards exist for the commercial printing industry. All printing facilities are required to meet the general pre-treatment standards for discharge of process wastewater. The general pre-treatment requirements prohibit the following: 1) pollutants that create a fire hazard in the POTW; 2) pollutants that will cause corrosive damage to the POTW; 3) pollutants (solid or viscous) in amounts that will obstruct flow in the POTW; 4) any pollutant released at a flow rate or concentration that interferes with the POTW operations (this includes oxygen-demanding pollutants); 5) effluents at a temperature that will inhibit biological activity in the POTW; 6) petroleum oils, non-biodegradable cutting fluid, or mineral oil products which will pass through the POTW or interfere with performance of chemicals in the POTW; 7) pollutants that result in toxic fumes within the POTW; and 8) any trucked or hauled pollutants. Facilities also areo required to notify the POTW within 24 hours if any violation of pre-treatment requirements occur. Often, state or local governments have additional reporting requirements, which should be addressed before discharge. Often, a NPDES permit is required even if no wastewater is produced on-site. If any stormwater comes into contact with industrial activity or construction activity, a permit will be necessary. This contact includes any handling equipment or activities, raw materials, intermediate products, final products, or industrial machinery exposed to stormwater that drains to a storm sewer system or directly to receiving waters. Note that a stormwater permit is not required for municipal systems that have combined wastewater and stormwater systems, but the POTW should be informed that industrial stormwater will be entering the sewers. Occupational Safety and Health Administration Act Under OSHA, employers (regardless of size) are required to meet several standards that will maintain a safe and healthful workplace. The general duty clause of OSHA states that a place of employment which is free from recognized hazards that are causing or are likely to cause death or serious physical harm must be provided to the employee. Section 1910.1200 of OSHA is the hazard communication standard and requires employers to inventory, classify and label all chemical substances on-site that are considered to be hazardous to health or have physical properties that are hazardous. All employers must have a written program available to employees that includes inspection, inventory, labeling, availability of material safety data sheets, employee training, agency reporting and record-keeping systems. Employers of fewer than 10 people may be exempt from the recordkeeping systems only. Several states have their own OSHA regulations, and it will therefore be necessary for facilities to contact their state agency to find their requirements. Superfund (Comprehensive Environmental Response, Compensation and Liability Act) (CERCLA) & Superfund Amendments and Reauthorization Act (SARA) Under the original Superfund, the EPA was authorized to undertake any measures necessary to address any hazard to human health and the environment triggered by burning, leaking or explosion of hazardous substances, contamination of food chains, or drinking water contamination. Toxic Substances Control Act (TSCA) Under TSCA, the EPA is given the authority to limit or prohibit the manufacture, processing, distribution or disposal of a chemical substance which EPA has determined poses a risk to human health or the environment. EPA also will gather information on all risks associated with toxicity of all new and existing chemicals. Section 4 is the authorization for the EPA to require testing of chemical substances or mixtures the agency determines could be a risk to human health or the environment. Section 5 grants the EPA the right to test all new chemical substances to determine their toxicity and subsequent risk 90 days before manufacturing, processing or importing of said chemical. Section 6 is the official notification that the EPA may regulate the manufacture, processing, distribution in commerce, and the use and disposal of any chemical substance determined to be toxic. Section 8 is the requirement for all users and manufacturers to keep records and submit reports to the EPA.
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