Inspection Panel: Common Violations and How to Avoid Them Jim - - PowerPoint PPT Presentation

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Inspection Panel: Common Violations and How to Avoid Them Jim - - PowerPoint PPT Presentation

Jun 22, 2023 39 likes •684 views

Inspection Panel: Common Violations and How to Avoid Them Jim Ferritto Waste Characterization Specialists M ichigan Department of Environmental Quality 1 Inspection Panel Wade OBoyle, Grand Rapids M ary Ann St. Antoine, M arquette

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Inspection Panel: Common Violations and How to Avoid Them

Jim Ferritto Waste Characterization Specialists M ichigan Department of Environmental Quality

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Inspection Panel

  • Wade O’Boyle, Grand Rapids
  • M ary Ann St. Antoine, M arquette
  • Jenny Bennett, Gaylord
  • Jill Coulter, Lansing
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Common Generator Violations

  • Waste Characterization
  • Waste Accumulation and Handling
  • Recordkeeping
  • Training
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Q: What is it? A: It ’s just water

(& some other stuff)

Waste Characterization

WADEO’BOYLE

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It ’s just Water?

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It ’s just Water?

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It ’s just Water?

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http://www.tampabay.com/news/environment/water/the-water-in-a-bottle-can-spring-from-just-about-anywhere/418792 https://www.nestle-watersna.com/asset-library/publishingimages/brands/ice%20mountain/icemountain_water_analysis.png

It ’s just Water?

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It ’s just Water?

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https://www.bellsbeer.com/beer/year-round/two-hearted-ale

It ’s just Water?

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It ’s just Water?

(& some other ??!)

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Q: What is it?

A: It ’s just water (& some other stuff)

“ Waste characterization”

  • I use “ water” to illustrate that specifics or characterization is important.
  • In the context of waste or byproducts, when someone says, “ it ’s just water (dirt,

wood, etc.)”, I have many questions (e.g. knowledge, tests, etc. ).

  • All of the examples are generally speaking, “ just water”, but also take on

individual identities.

  • Details make all the difference (& some other stuff) :
  • Fishy water, carbonated flavored water, water with flavoring & vitamins, spring water

(contains carbonates, iron, etc.), caffeine etc. , flavored water & alcohol, and waste water.

  • It’s NEVER JUST WATER!
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Generators of Hazardous W aste have “Cradle to Grave” responsibility!!!

Think about W HEN AN D W HERE a Product or Chemical would be considered a “waste” (This is a time and a place!). Gum N ote: N icotine is a listed Hazardous W aste P075 “acute hazardous waste”

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The Riddle of the Sphinx:

"W hat walks on four legs in the morning, two legs in the afternoon, three legs in the evening, and no legs at night? "

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Know your own Waste & M anage it Properly

Hazardous because:

1. Listed 2. Characteristic (test)

You know because:

1. Knowledge 2. Tests

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Know your own Waste & M anage it properly

  • The KEY- Documentation! Documentation!

Documentation!

  • If Hazardous- WHY? Document!!! Include knowledge

AND lab results (always representative sampling)

  • If Non-Hazardous- WHY? Document!!! Include

knowledge AND lab results (always representative sampling)

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Waste Characterization Record

To meet the waste characterization recordkeeping requirements in rules:

  • Create a record that details your answers to the

waste characterization questions asked in Rules 212 and 213

  • Detail must thoroughly document your determination
  • Detail are in addition to the records necessary for

OSHA safety

  • Records should be assembled and readily available at

the site of generation for each waste stream

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Waste Characterization Record

Waste characterization record should include:

  • waste type/ name
  • narrative description of the waste
  • source of waste
  • test result(s) obtained from sampling and analyzing the waste
  • description of the sampling procedure(s) used for waste testing
  • details on how the sample was determined to be

representative of the waste stream

  • a copy of Safety Data Sheets (SDS) or other reference materials

relied upon for making the waste determination, including calculations used to evaluate subpart BB and CC applicability (to determine the ppmv volatile organic compound content of the waste)

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Waste Protected from Weather, Fire, Physical Damage and Vandals

Mary Ann St. Antoine

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Rules require that the generator ensures that the area where the waste is accumulated is protected from weather, fire, physical damage, and vandals.

M ichigan weather: predictably unpredictable

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Look up! Damage from falling ice Damage from snow plows and careless drivers

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Vandals

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Keep IBC Totes, drums and containers stored securely away from driveways, alleys and public access.

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Good Housekeeping Prevents Fires

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Fuel for fires

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Ignition Source

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Ignition source

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Fire, Explosion or Discharge Fire, Explosion or Discharge

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Fire, Explosion or Discharge

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Fire, Explosion or Discharge

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Labeling & Closed Containers

AKA

Where’s M y Label? and How Closed is Closed?

J ENNY BENNETT

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Where’s M y Label?

Great Question…

  • On the shelf above the

accumulation containers?

  • Stapled to my

transporter’s invoice?

  • Filed with last year’s tax

documents?

  • Locked in the office of a

staff member on extended leave?

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Satellite or 90/ 180 Day Accumulation Area

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How Closed is Closed?

  • Why would the regulations

require my container to be closed?

  • What am I trying to prevent?
  • How can I make it easier for

my employees to comply?

  • How can I be more efficient?
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Waste Considerations

Liquid vs Solid? Access Needed M ultiple Times per Day or Once per Week?

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Accumulated

Happily Ever After!

(actually 270 days or less, depending on your generator status & location, unless you are a CESQG)

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Training

Hazardous Waste Part 111 JILL COULTER

KE Y to Success

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Hazardous Waste Generator Compliance Summary

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Web Resources

  • Go to www.michigan.gov/ deqwaste

Select “ Hazardous” tab on the left Select “ Hazardous and Liquid Industrial Waste M anagement” to access resources and statutes/ rules

  • Go to www.michigan.gov/ deqretail
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Self Certification Form

Trainer Training - Recorded Webinars

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Training Resources

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DEQ Guidebook

Go to www.michigan. gov/ehsguide

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Different Areas of Training JOB DISCRIPTION

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Large Quantity Generator

Training Requirements The generator complies with the requirements for owners or operators of interim status facilities in 40 CFR 265 subparts C and D (preparedness prevention & contingency planning), §265.16 (personnel training and part 268 (land disposal restrictions)

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LQG employee training documents:

  • Must have written hazardous waste training

program

  • Must conduct annual training for employees
  • Must keep written training records for 3 years
  • Training must be conducted by someone qualified

to give training

  • Must have description of the type of training given

Large Quantity Generator

Training Requirements

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Small Quantity Generator

Training Requirements

The generator shall ensure employees are thoroughly familiar with proper waste handling and emergency procedures relevant to their responsibilities during normal facility

  • perations and emergencies
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Conditionally Exempt Small Quantity Generator

Training Requirements

CESQGs do not have any specific training requirements but are encouraged to train regularly to ensure they can safely manage waste during normal operations and during emergencies

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Preparing/ Offering Waste for Transport

Requires Training to meet:

  • Part 111, Hazardous Waste Training
  • 49 CFR US DOT Training

See Chapter 4 of guidebook also available

  • n-line at www.michigan.gov/ ehsguide
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Environmental Emergencies

Prepare for reporting an environmental emergency by reviewing the Release Reporting Table at www.michigan.gov/ chemrelease When in doubt whether to report or when a release impacts waters of the state, notify:

  • Your local emergency responders at 911
  • DEQ Pollution Emergency Alert System (PEAS) at

800-292-4706 (within Michigan) or 517-373-7660 (outside Michigan)

  • EPA National Response Center at 800-424-8802
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Environmental Emergencies

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Generator Satellite Accumulation

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Generator Accumulation Area

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Labeling

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Questions?