Managing Waste at Your Facility

Most metal finishing facilities accumulate some hazardous waste on site for a short period of time and then ship it off site to a treatment, storage, or disposal facility (TSDF).

Accumulating Your Waste

Accumulating hazardous waste on site can pose a threat to human health and the environment, so you may only keep it for a short time without a permit. Before shipping the waste for disposal or recycling, you are responsible for its safe management, which includes:

• Storage
• Preventing Accidents
• Responding to Emergencies

Very small quantity generators (VSQG) may not store more than 2,200 lbs. (1,000 kg) of hazardous waste on site at any time. Also, you must ensure delivery of your hazardous waste to an offsite treatment or disposal facility that is one of the following:

• A state or federally regulated hazardous waste management treatment, storage, or disposal facility (TSDF).
• A facility permitted, licensed, or registered by a state to manage municipal or industrial solid waste.

• A facility that uses, reuses, or legitimately recycles the waste (or treats the waste prior to use, reuse, or recycling).

• A universal waste handler or destination facility subject to the universal waste requirements (40 CFR Part 273).

Small quantity generators (SQGs) can accumulate no more than 13,228 lbs. (6,000 kg) of hazardous waste on site for up to 180 days without a permit. You can accumulate this amount of waste for up to 270 days if you must transport it more than 200 miles away for recovery, treatment, or disposal. Limited extensions may be granted by the state director or the regional EPA administrator. If you exceed these limits, you are considered a TSDF and must obtain an operating permit.

SQGs must accumulate waste in tanks or containers, such as 55-gallon drums. Your storage tanks and containers must be managed according to EPA requirements summarized below.

For containers (e.g., drums) you must:

• Label each container with the words "HAZARDOUS WASTE," and mark each container with the date the waste was generated.

• Use a container made of, or lined with, a material that is compatible with the hazardous waste to be stored. (This will prevent the waste from reacting with or corroding the container.)

• Keep all containers holding hazardous waste closed during storage, except when adding or removing waste. Do not open, handle, or store (stack) containers in a way that might rupture them, cause them to leak, or otherwise fail.

• Inspect areas where containers are stored at least weekly. Look for leaks and for deterioration caused by corrosion or other factors.

• Maintain the containers in good condition. If a container leaks, put the hazardous waste in another container, or contain it in some other way that complies with EPA regulations.

• Do not mix incompatible wastes or materials unless precautions are taken to prevent certain hazards.

For tanks, you must (applicable to SQGs and large quantity generators (LQGs):

• Label each tank with the words "HAZARDOUS WASTE."

• Store only waste that will not cause the tank or the inner liner of the tank to rupture, leak, corrode, or fail.

• Equip tanks that have an automatic waste feed with a waste feed cutoff system, or a bypass system for use in the event of a leak or overflow.

• Inspect discharge control and monitoring equipment and the level of waste in uncovered tanks at least once each operating day. Inspect the tanks and surrounding areas for leaks or other problems (such as corrosion) at least weekly.

• Use the National Fire Protection Associations (NFPAs) buffer zone requirements for covered tanks containing ignitable or reactive wastes. These requirements specify distances considered to be safe buffer zones for various ignitable or reactive wastes. You can reach the NFPA at 617-770-3000.

• Do not mix incompatible wastes or materials unless precautions are taken to prevent certain hazards.

• Do not place ignitable or reactive wastes in tanks unless certain precautions are taken.

• Provide at least two feet (60 centimeters) of freeboard (space at the top of each tank) in uncovered tanks, unless the tank is equipped with a containment structure, a drainage control system, or a standby tank with adequate capacity.

Additional tank storage requirements for LQGs:

• If hazardous waste is continuously fed into a tank, it must be equipped with a means of stopping inflow, such as a waste feed cutoff or a bypass system to a standby truck.

• Additional inspection requirements. At least daily, inspect:
  • Discharge control equipment

  • Data gathered by monitoring equipment

  • Level of waste in the tank

• Additional inspection requirements. At least weekly, inspect:
  • Construction materials of the tank to see if it is corroding or leaking

  • Construction materials of the area surrounding the tank for signs of corrosion or leaks

The complete regulations with regard to storage are found in 40 CFR 262.34.

Preventing Accidents

Whenever you store hazardous waste on site, you must minimize the potential risks from fires, explosions, or other accidents.

All SQGs and LQGs that store hazardous waste on site must be equipped with:

• An internal communications or alarm system capable of providing immediate emergency instruction (voice or signal) to all personnel.
• A device, such as a telephone (immediately available at the scene of operations) or a hand-held, two-way radio, capable of summoning emergency assistance from local police and fire departments or emergency response teams.
• Portable fire extinguishers, fire control devices (including special extinguishing equipment, such as that using foam, inert gas, or dry chemicals), spill control materials, and decontamination supplies.
• Water at adequate volume and pressure to supply water hose streams, foam-producing equipment, automatic sprinklers, or water spray systems.

You must test and maintain all equipment to ensure proper operation. Allow sufficient aisle space to permit the unobstructed movement of personnel, fire protection equipment, spill control equipment, and decontamination equipment to any area of facility operation. Attempt to secure arrangements with fire departments, police, emergency response teams, equipment suppliers, and local hospitals, as appropriate, to provide services in the event of an emergency. Ensure that personnel handling hazardous waste have immediate access to an alarm or emergency communications device.

Responding to Emergencies

You must be prepared for an emergency at your facility. One way is to develop a contingency plan, which is a requirement for LQGs. A contingency plan usually answers a set of "what if" questions. For example: "What if there is a fire in the area where hazardous waste is stored?" or "What if I spill hazardous waste, or one of my hazardous waste containers leaks?" Although EPA does not require SQGs to develop a written contingency plan, in case of a fire, explosion, or toxic release, having such a plan would provide an organized and coordinated course of action. EPA does require SQGs to establish basic safety guidelines and response procedures to follow in the event of an emergency.

If you think you have an emergency, immediately call the National Response Center at 800 424-8802. The NRC is the sole federal point of contact for reporting oil and chemical spills.

In the event of a fire, explosion, or other release of hazardous waste that could threaten human health outside the facility, or if you think that a spill has reached surface water, call the National Response Center to report the emergency. The Response Center will evaluate the situation and help you make appropriate emergency decisions. In many cases, you will find that the problem you faced was not a true emergency, but "it is better to call if you are not sure." Stiff penalties exist for failing to report emergencies.