1 Waste-Related and Other Regulations in Pennsylvania Prepared For CATALYST CONNECTION WEBINAR SERIES Presented By Civil & Environmental Consultants, Inc. Paul W. Tomiczek III, REM, P.E. Vice President David J. Larson Project Manager November 20, 2014
2 Introduction CEC is a Multi-Disciplinary Consulting & Engineering Firm 25 th Year in business in 2014 Consistently ranked highly among the Engineering News-Record s Top 200 Environmental Firms List and Top 500 Design Firms List Named a Top Workplace in Pittsburgh and Nashville
3 Introduction More Than 650 Employees in 19 Cities 1. Austin, TX 2. Bridgeport, WV 3. Boston, MA 4. Charlotte, NC 5. Chicago, IL 6. Cincinnati, OH 7. Columbus, OH 8. Detroit, MI 9. Export, PA 10. Indianapolis, IN 11. Knoxville, TN 12. Nashville, TN 13. Philadelphia, PA 14. Phoenix, AZ 15. Pittsburgh, PA 16. Sayre, PA 17. Sevierville, TN 18. St. Louis, MO 19. Toledo, OH
4 Introduction Our Service Areas The Clients We Serve Civil Engineering & Survey Environmental Engineering & Sciences Ecological Sciences Waste Management Water Resources Manufacturing Mining Natural Gas Power Public Sector Real Estate Solid Waste
5 Webinar Introduction This webinar will focus on waste-related issues and several other regulatory program areas. There are many state and federal regulations that may apply to a manufacturing facility. This webinar will review a selection of the regulations.
6 Agenda 1. Resource Conservation and Recovery Act (RCRA) regulations address hazardous waste identification procedures, recycling exemptions, universal wastes, used oils and waste oils, and generator requirements for labeling, accumulating, and manifesting wastes; 2. Pennsylvania Residual Waste regulations (Chapter 287) govern the management, disposal, and reporting of industrial wastes; 3. Preparedness, Prevention, and Contingency (PPC) Plan requirements are intended to help prevent the release of wastes or other chemicals and petroleum products that could result in contamination of groundwater and surface water, and prepare facilities to address accidental releases that may occur; 4. Emergency Planning and Community Right-to-Know Act (EPCRA) regulations cover the storage and use of most chemicals at industrial facilities when they exceed certain threshold values, including submittal of Tier II Chemical Inventory Reports and Toxic Release Inventory Forms; and 5. Toxic Substances Control Act (TSCA) regulations pertain to new chemical manufacturing and submitting Chemical Data Report (CDR) forms for the manufacture of chemicals above certain thresholds, as well as regulations related to the use of Polychlorinated Biphenyls (PCBs) at industrial sites.
7 RCRA - Hazardous Waste Identification Hazardous Waste Identification Process Proper hazardous waste identification is essential to the success of the RCRA program. This identification process can be a very complex task. Therefore, it is best to approach the issue by asking a series of questions in a step-wise manner. 1. Is the material in question a solid waste? 2. Is the material excluded from the definition of solid waste or hazardous waste? 3. Is the waste a listed or characteristic hazardous waste? 4. Is the waste delisted?
8 RCRA - Hazardous Waste Identification Is the Material a Solid Waste? Recycled Materials Secondary Materials Sham Recycling
9 RCRA - Hazardous Waste Identification Recycled Wastes May or May Not Be Solid Wastes
10 RCRA - Hazardous Waste Identification Is the Waste Excluded? Determining whether or not a waste is excluded or exempted from hazardous waste regulation is the second step in the RCRA hazardous waste identification process. There are five categories of exclusions: Solid Waste Exclusions Hazardous Waste Exclusions Raw Material, Product Storage, and Process Unit Waste Exclusions Sample and Treatability Study Exclusions Dredged Material Regulated under the Marine Protection Research and Sanctuaries Act or the Clean Water Act
11 RCRA - Hazardous Waste Identification Solid Waste Exclusions (Examples) Domestic Sewage and Mixtures of Domestic Sewage Industrial Wastewater Discharges (Point Source Discharges) Irrigation Return Flows Pulping Liquors Spent Sulfuric Acid Closed-Loop Recycling Certain Coke By-Product Wastes Processed Scrap Metal Shredded Circuit Boards Zinc Fertilizer from Recycled Hazardous Secondary Materials
13 RCRA - Hazardous Waste Identification Raw Material, Product Storage, and Process Unit Waste Exclusions Hazardous wastes generated in raw material, product storage, or process (e.g., manufacturing) units are exempt from Subtitle C hazardous waste regulation while the waste remains in such units. These units include tanks, pipelines, vehicles, and vessels used either in the manufacturing process or for storing raw materials or products, but specifically do not include surface impoundments. Once the waste is removed from the unit, or when a unit temporarily or permanently ceases operation for 90 days, the waste is considered generated and is subject to regulation.
14 RCRA - Hazardous Waste Identification Waste Sample and Treatability Study Sample Exclusions Hazardous waste samples are small, discrete amounts of hazardous waste that are essential to ensure accurate characterization and proper hazardous waste treatment. In order to facilitate the analysis of these materials, RCRA exempts characterization samples and treatability study samples from Subtitle C hazardous waste regulation.
15 RCRA - Hazardous Waste Identification Is the Waste a Listed Hazardous Waste? After a facility determines that its waste is a solid waste and is not excluded from the definitions of solid or hazardous waste, the owner and operator must determine if the waste is a hazardous waste. The first step in this process is determining if the waste is a listed hazardous waste. The hazardous waste listings consist of four lists: the F, P, K, and U lists
16 Listing Criteria - The hazard codes indicating the basis for listing a waste are: Toxic Waste (T) Acute Hazardous Waste (H) Ignitable Waste (I) Corrosive Waste (C) Reactive Waste (R) Toxicity Characteristic Waste (E)
17 RCRA - Hazardous Waste Identification Hazardous Waste Lists The F list The F list includes wastes from certain common industrial and manufacturing processes. Because the processes generating these wastes can occur in different sectors of industry, the F list wastes are known as wastes from nonspecific sources. The F list is codified in the regulations in 40 CFR The K list The K list includes wastes from specific industries. As a result, K list wastes are known as wastes from specific sources. The K list is found in 40 CFR
18 RCRA - Hazardous Waste Identification The P list and the U list These two lists include pure or commercial grade formulations of specific unused chemicals. Chemicals are included on the P list if they are acutely toxic. A chemical is acutely toxic if it is fatal to humans in low doses, if scientific studies have shown that it has lethal effects on experimental organisms, or if it causes serious irreversible or incapacitating illness. The U list is generally comprised of chemicals that are toxic, but also includes chemicals that display other characteristics, such as ignitability or reactivity. Both the P list and U list are codified in 40 CFR
19 RCRA - Hazardous Waste Identification Waste Listed Solely for Exhibiting the Characteristic of Ignitability, Corrosivity, and/or Reactivity Hazardous wastes listed solely for exhibiting the characteristic of ignitability, corrosivity, and/ or reactivity are not regulated the same way that other listed hazardous wastes are regulated under RCRA. When a waste meets a listing description for one of the 29 wastes listed solely for exhibiting the characteristic of ignitability, corrosivity, and/or reactivity, the waste is not hazardous if it does not exhibit that characteristic at the point of generation.
20 RCRA - Hazardous Waste Identification Delisting Petitions The RCRA regulations provide a form of relief for listed wastes with low concentrations of hazardous constituents. Through a site-specific process known as delisting, a waste handler can submit to an EPA region or authorized state a petition demonstrating that, even though a particular wastestream generated at its facility is a listed hazardous waste, it does not pose sufficient hazard to merit RCRA regulation.
21 RCRA - Hazardous Waste Identification Is the Waste a Characteristic Hazardous Waste? Ignitability Corrosivity Reactivity Toxicity
22 RCRA - Hazardous Waste Identification Ignitability The ignitability characteristic identifies wastes that can readily catch fire and sustain combustion. Many paints, cleaners, and other industrial wastes pose such a hazard. Liquid and non-liquid wastes are treated differently by the ignitability characteristic. The flash point test determines the lowest temperature at which the fumes above a waste will ignite when exposed to flame. Liquid wastes with a flash point of less than 60 C (140 F) in closed-cup test are ignitable. Many wastes in solid or non-liquid physical form (e.g., wood or paper) can also readily catch fire and sustain combustion, but EPA did not intend to regulate most of these non-liquid materials as ignitable wastes. A non-liquid waste is considered ignitable only if it can spontaneously catch fire or catch fire through friction or absorption of moisture under normal handling conditions and can burn so vigorously that it creates a hazard.
23 RCRA - Hazardous Waste Identification Corrosivity The corrosivity characteristic identifies wastes that are acidic or alkaline (basic). Such wastes can readily corrode or dissolve flesh, metal, or other materials. Aqueous wastes with a ph greater than or equal to 12.5 or less than or equal to 2 are corrosive. A liquid waste may also be corrosive if it has the ability to corrode steel under specific conditions. Corrosive wastes carry the waste code D002. The regulations describing the corrosivity characteristic are found in 40 CFR
24 RCRA - Hazardous Waste Identification Reactivity The reactivity characteristic identifies wastes that readily explode or undergo violent reactions or react to release toxic gases or fumes. A waste is reactive if it meets any of the following criteria: o It can explode or violently react when exposed to water or under normal handling conditions o It can create toxic fumes or gases at hazardous levels when exposed to water or under normal waste handling conditions o It can explode if heated under confinement or exposed to a strong igniting source, or it meets the criteria for classification as an explosive under DOT rules o It generates toxic levels of sulfide or cyanide gas when exposed to a ph range of 2 through 12.5 Wastes exhibiting the characteristic of reactivity assigned the waste code D003. The reactivity characteristic is described in the regulations in 40 CFR
25 RCRA - Hazardous Waste Identification Toxicity When hazardous waste is disposed of in a land disposal unit, toxic compounds or elements can leach into underground drinking water supplies and expose users of the water to hazardous chemicals and constituents. EPA developed the toxicity characteristic to identify wastes likely to leach dangerous concentrations of toxic chemicals into ground water. A lab procedure was developed to evaluate the leaching properties of waste, the Toxicity Characteristic Leaching Procedure (TCLP). The regulations describing the toxicity characteristic are codified in 40 CFR , and the TC regulatory levels appear in Table 1 of that same section.
26 RCRA - Hazardous Waste Identification
27 RCRA - Hazardous Waste Identification Mixture Rule The mixture rule is intended to ensure that mixtures of listed wastes with nonhazardous solid wastes are regulated in a manner that minimizes threats to human health and the environment Listed Wastes: The mixture rule regulates a combination of any amount of a nonhazardous solid waste and any amount of a listed hazardous waste as a listed hazardous waste Characteristic Wastes: The mixture rule applies differently to listed and characteristic wastes. A mixture involving characteristic wastes is hazardous only if the mixture itself exhibits a characteristic.
28 RCRA - Hazardous Waste Identification Mixture Rule (Continued) Wastes Listed solely for exhibiting the characteristic of Ignitability, corrosivity, and/or Reactivity: All wastes listed solely for exhibiting the characteristic of ignitability, corrosivity and/ or reactivity characteristic are not regulated as hazardous wastes once they no longer exhibit a characteristic. If a hazardous waste listed only for a characteristic is mixed with a solid waste, the original listing does not carry through to the resulting mixture if that mixture does not exhibit any hazardous waste characteristics. De Minimis Exemptions may apply in some cases.
29 RCRA - Hazardous Waste Identification Derived From Rule: Listed Wastes: EPA created the derived-from rule which states that any material derived from a listed hazardous waste is also a listed hazardous waste Characteristic Wastes: Treatment residues and materials derived from characteristic wastes are hazardous only if they themselves exhibit a characteristic.
30 RCRA Universal Wastes Universal Waste Universal wastes are subject to management provisions intended to ease the management burden and facilitate the recycling or proper treatment and disposal of such materials. Four types of waste are covered under universal waste regulations: hazardous waste batteries, hazardous waste pesticides that are either recalled or collected in waste pesticide collection programs, hazardous waste mercurycontaining equipment, and hazardous waste lamps. Universal Waste Management Standards are discussed at 40 CFR Part 273
31 RCRA Used Oil/Waste Oil Used oil is any oil that has been refined from crude oil or any synthetic oil that has been used and, as a result of such use, is contaminated by physical or chemical impurities. Used Oil Management Standards are discussed at 40 CFR Part 279 Pennsylvania regulations require Used Oil to be labeled as Waste Oil.
32 RCRA Electronics Waste Disposal In November 2010, the Pennsylvania General Assembly passed the Covered Device Recycling Act (CDRA), which establishes a number of requirements for individuals and entities involved throughout the life cycle of certain covered electronic devices. Covered devices include items such as: desktop computers, laptop computers, computer monitors, computer peripherals and televisions.
33 RCRA Electronics Waste Disposal Beginning Jan. 24, 2013, a disposal ban on covered devices went into effect in Pennsylvania. Business may not dispose of a covered device with their municipal solid waste. These devices and their components must be properly recycled and may not be taken to (or accepted by) landfills or other solid waste disposal facilities for disposal.
34 RCRA Generator Categories and Requirements Who Are The Regulated Generators? Large Quantity Generators Small Quantity Generators Conditionally Exempt Small Quantity Generators Episodic Generation State Regulations
35 RCRA Generator Categories and Requirements Large Quantity Generators (LQGs) Large quantity generators are defined as those facilities that generate: o 1,000 kg or more of hazardous waste per calendar month (approximately 2,200 lbs) OR o 1 kg or more of acutely hazardous waste per calendar month (approximately 2.2 lbs).
36 RCRA Generator Categories and Requirements Small Quantity Generators (SQGs) SQGs are defined as those facilities that: Generate between 100 kg (approximately 220 lbs) and 1,000 kg of hazardous waste per calendar month AND Accumulate less than 6,000 kg (approximately 13,200 lbs) of hazardous waste at any time.
37 RCRA Generator Categories and Requirements Conditionally Exempt Small Quantity Generators (CESQGs). These generators are defined as those facilities that produce: 100 kg or less of hazardous waste per calendar month OR 1 kg or less of acutely hazardous waste per calendar month. Beyond the monthly generation limits, the CESQG requirements additionally limit the facility s total waste accumulation quantities to 1,000 kg of hazardous waste, 1 kg of acute hazardous waste, or 100 kg of any residue from the cleanup of a spill of acute hazardous waste at any time.
38 RCRA Generator Categories and Requirements Because generator status is determined on a monthly basis, it is possible that a generator s status can change from one month to the next, depending on the amount of waste generated in a particular month. This is referred to as episodic generation. If a generator s status does in fact change, the generator is required to comply with the respective regulatory requirements for that class of generators for the waste generated in that particular month.
39 RCRA Generator Categories and Requirements Large and Small Quantity Generator Regulatory Requirements Waste Identification and Counting EPA Identification Numbers Accumulation of Waste Preparation for Transport Regulations Manifest Recordkeeping and Reporting Quantity and Time Limits for Storage of Wastes
40 RCRA Generator Categories and Requirements General Facility Standards EPA Identification Numbers Waste Analysis Security Inspection Requirements Personnel Training Requirements for Ignitable, Reactive, or Incompatible Waste Location Standards
41 RCRA Generator Categories and Requirements Preparedness and Prevention Contingency Plans and Emergency Procedures Contingency Plan Emergency Coordinator Emergency Procedures
42 RCRA Generator Categories and Requirements
43 RCRA TSDF Standards and Requirements Standards for Hazardous Waste Treatment Storage, and Disposal Units Containers Containment Buildings Drip Pads Land Treatment Units Landfills Surface Impoundments Tanks Waste Piles
44 RCRA - References EPA RCRA Hotline Training Modules EPA RCRA Orientation Manual Electronic Code of Federal Regulations 40 CFR
45 PA Residual Waste Regulations Regulations are covered in Chapter 287. Responsibilities under these regulations include proper waste characterization, management and disposal. Source reduction strategy planning (25R) is also required under the PA residual waste regulations. Reporting obligations include biennial residual waste reporting and annual 26R reporting.
46 Form 26R - Chemical Analysis of Residual Waste Annual Report by the Generator Residual waste Garbage, refuse, other discarded material or other waste, including solid, liquid, semisolid or contained gaseous materials resulting from industrial, mining and agricultural operations and sludge from an industrial, mining or agricultural water supply treatment facility, wastewater treatment facility or air pollution control facility, if it is not hazardous.
47 Form 26R Types of Residual Waste Combustion Residues Metallurgical Process Residues Sludges, Scales Chemical Wastes Generic Manufacturing Wastes Wood Wastes Process Wastewaters Grease Special Handling Wastes Asbestos Containing Waste Waste Tires Industrial Equipment, Maintenance Waste/Scrap Do Not Report: sanitary sewage or uncontaminated non-contact cooling waters; office, lunchroom, or restroom wastes; construction/demolition debris
48 Form 26R - Chemical Analysis of Residual Waste Annual Report by the Generator SECTION A. CLIENT (GENERATOR OF THE WASTE) INFORMATION Company Name Contact Information Waste Generation Location SECTION B. WASTE DESCRIPTION General Properties: o ph Range o Physical State o Physical Appearance Amount and Unit of Measure Residual Waste Code
49 Form 26R Residual Waste Codes The list of Residual Waste Codes (RWC) can be found on the Codes Residual Waste PADEP document 2540-PM-BWM040 Also include: code s description, the amount of waste, the unit of measurement, and the timeframe for disposal/processing.
50 Form 26R SECTION B. WASTE DESCRIPTION (Continued) Chemical Analysis Attachments o Detailed Chemical Characterization o Description of Waste Sampling Method o Laboratory QA/QC procedures o Hazardous Waste Determination o Generator Knowledge in Lieu of Chemical Analysis
51 Form 26R SECTION B. WASTE DESCRIPTION (Continued) Process Description & Schematic Attachments o Manufacturing and/or pollution Control Processes o Schematic Detailing Waste Production o Confidentiality Claim
52 Form 26R SECTION C. MANAGEMENT OF RESIDUAL WASTE Processing Or Disposal Facilities Beneficial Use o General Permit Number o Approval Number o Volume of Waste SECTION D. CERTIFICATION General Properties Chemical Analysis Process Description
53 Form 26R Department of Environmental Protection Southeast Regional Office 2 East Main Street Norristown, PA Phone (484) Northeast Regional Office 2 Public Square Wilkes-Barre, PA Phone (570) Southcentral Regional Office 909 Elmerton Avenue Harrisburg, PA Phone (717) Southwest Regional Office 400 Waterfront Drive Pittsburgh, PA Phone (412) Northcentral Regional Office 208 W. 3rd St., Suite 101 Williamsport, PA Phone (570) Northwest Regional Office 230 Chestnut Street Meadville, PA Phone (814)
54 Form 26 R - References PADEP Form 26R Chemical Analysis Of Residual Waste Annual Report By The Generator; 2540-PM-BWM0347 Rev. 1/2011 PADEP Form 26R Chemical Analysis Of Residual Waste Annual Report By The Generator Instructions; 2540-PM- BWM0347 Rev. 7/2010 PADEP Residual Waste Codes (RWC); 2540-PM-BWM0404 Rev. 8/ Pa. Code Section 287 Residual Waste Management General Provisions - oc.html
55 Preparedness, Prevention, and Contingency (PPC) Plan 1. Who needs to develop and implement a PPC Plan? 2. What is a PPC Plan?
56 Who needs to develop and implement a PPC Plan? Pennsylvania industrial and commercial installations which have the potential for causing accidental pollution of air, land, or water, or the endangerment of public health and safety are required to develop and implement. Authority: The Federal Clean Water Act, Pennsylvania Clean Streams Law, Pennsylvania Solid Waste Management Act, Pennsylvania Storage Tank and Spill Prevention Act, and Federal Oil Pollution Act
57 Who needs to develop and implement a PPC Plan? Pennsylvania industrial and commercial installations: applying for an NPDES Storm Water Discharge General Permit, Industrial Wastewater Discharge Permit, or Water Management Permit; that are non-npdes facilities directed by the DEP to develop a PPC plan (on a case-by-case basis); that have regulated storage tank(s) with an aggregate aboveground storage capacity > 21,000 gallons [note: a Spill Prevention Response (SPR) plan is also required]; or that generate hazardous waste, or which involve treatment, recycling, storage, or disposal of hazardous waste [note: generators, of between 100 and 1,000 kilograms of hazardous waste per month, may not be required to have a PPC plan if they comply with the Preparedness and Prevention requirements in the regulations
58 PPC Plan - Policy To plan and provide effective and efficient response to emergencies and accidents for any situation dealing with public health, safety, and the environment.
59 PPC Plan - Purpose To improve and preserve the purity of the Waters of the Commonwealth by prompt adequate response to all emergencies and accidental spills of polluting substances for the protection of public health, animal and aquatic life and for recreation. Many manufacturing and commercial activities have the potential for causing environmental degradation or endangerment of public health and safety through accidental releases of toxic, hazardous, or other polluting materials.
60 PPC Plan Water-Related Considerations Purpose: prevention/control of accidental discharge of polluting materials to surface water or groundwater Covered Activities: all industrial activities having potential for accidental pollution transportation, storage, processing of raw materials, intermediates, products, fuels, wastes Hazards Addressed: container leaks, ruptures, spills, floods, power failures, mechanical failure, human error, strikes, vandalism
61 PPC Plan Waste-Related Considerations Purpose: minimize and abate hazards to human health and the environment from fires, explosions, or release of solid wastes to air, soil, or surface water Covered Activities: generating, storing, recycling, treating, transporting, or disposing of solid wastes, hazardous wastes, residual wastes, municipal wastes, or medical wastes Hazards Addressed: container leaks, ruptures, spills, floods, power failures, mechanical failure, human error, strikes, vandalism, fires, explosions
62 PPC Plan Other Emergency Response Plans Oil-related Spill Prevention, Control, and Countermeasure (SPCC) plans, which are or have been developed pursuant to EPA s oil-related SPCC regulations, can be incorporated into a PPC plan; as can other emergency response plans (e.g. PIPPs and SWPPPs). Likewise, the additional downstream notification requirement of an Spill Prevention Response (SPR) plan can be added to an existing plan to satisfy the Storage Tank and Spill Prevention Act, providing all required elements of a SPR plan are completed for the existing plan.
63 PPC Plan - Submission to PADEP NPDES dischargers should submit (2) copies of the PPC plan for review, along with the NPDES application materials. All Stormwater General Permit applicants must complete and implement the Plans before or at the same time as application submission. Facilities which are not required to obtain NPDES permits, but which must obtain Water Quality Protection Part II permits, should submit (2) copies of the PPC plan for review, along with the Part II permit application. Other facilities which are not normally required to obtain NPDES or WQM Part II permits may also be required to develop and submit a PPC Plan, should conditions warrant, pursuant to Chapter 92 of the Department s regulations.
64 PPC Plan - Submission to PADEP Hazardous waste generators are required to develop PPC plans and to maintain them on site. They are required to submit PPC plans to the Department for review upon request by the Department. Hazardous waste treatment, recycling, storage, or disposal facilities should submit one copy of the PPC plan for each copy of the Hazardous Waste Part B permit application being submitted. Residual and/or municipal waste disposal/processing/transfer/ composting facilities are required to develop and submit a PPC Plan as part of the residual and/or municipal waste permit application. Facilities permitted under permit-by-rule are required to develop PPC Plans and maintain them on site. Aboveground storage tank facilities (with aggregate capacity >21,000 gallons) are required to submit one copy of the SPR plan to the appropriate regional DEP office for review.
65 PPC Plan - Distribution A copy of the plan and any subsequent revisions must be maintained on-site. All members of the installation s organization responsible for implementing and maintaining the plan and all emergency coordinators must review the plan and be thoroughly familiar with provisions. PPC and other facility plans should be made available to the following agencies, to the extent which they may become involved in an actual emergency: 1. County and Local Emergency Management Agencies 2. Local Fire Service Agencies and/or Hazmat Team 3. Local Emergency Medical Service Agencies 4. Local Police
66 PPC Plan - Content and Format Effectiveness depends upon simplicity and readability Diagrams, charts, tables, maps, and plans must be legible and understandable, particularly in times of an actual emergency Indexed or tabbed for quick reference in an emergency
67 PPC Plan - Description of Facility 1. Description of the Industrial or Commercial Activity 2. Description of Existing Emergency Response Plans 3. Material and Waste Inventory 4. Pollution Incident History 5. Implementation Schedule for Plan Elements Not Currently in Place
68 PPC Plan - Implementation Description of How Plan is Implemented by Organization 1. Organizational Structure of Facility for Implementation 2. List of Emergency Coordinators 3. Duties and Responsibilities of the Coordinator 4. Chain of Command
69 PPC Plan - Spill Leak Prevention and Response 1. Pre-Release Planning 2. Material Compatibility 3. Inspection and Monitoring Program 4. Preventive Maintenance 5. Housekeeping Program 6. Security 7. External Factor Planning 8. Employee Training Program
70 PPC Plan - Countermeasures 1. Countermeasures to be Undertaken by Facility 2. Countermeasures to be Undertaken by Contractors 3. Internal and External Communications and Alarm Systems 4. Evacuation Plan for Installation Personnel 5. Emergency Equipment Available for Response
71 PPC Plan - Emergency Spill Control Network 1. Arrangements with Local Emergency Response Agencies 2. Notification Lists 3. Downstream Notification Requirement for Storage Tanks (>21,000 gallons of regulated substances)
72 PPC Plan DEP Notification
73 PPC Plan - Certification Requirements for Non- Storm Water Discharges Provide a certification that the discharge has been tested or evaluated for the presence of nonstormwater discharges, including the identification of potential significant sources of non-stormwater at the site Except for sources including: fire-fighting activities; fire hydrant flushing; irrigation drainage; lawn watering; routine external building washdown which does not use detergents or other compounds; uncontaminated air conditioning or compressor condensate
74 PPC Plan - Storm Water Management Practices Description of BMPs to control storm water runoff and prevent storm water pollution that are reasonable and appropriate, and will be implemented and maintained Traditional measures reduce pollutant discharges by reducing the volume of storm water discharges, such as swales, or preventing storm water run-on in areas of industrial activities Low cost measures may include: diverting rooftop or other drainage across grass swales, cleaning catch basins, and installing and maintaining oil and grit separators.
75 PPC Plan - Sediment and Erosion Prevention Identify areas which, due to topography, activities, or other factors, have a high potential for significant soil erosion, and identify measures to limit erosion. Develop and implement sediment and erosion prevention and control measures in accordance with Chapter 102 of the Department s rules and regulations and the Bureau of Soil and Water Conservation s Erosion and Sediment Pollution Control Program Manual.
76 PPC Plan - Additional Requirements for EPCRA, Section 313 Facilities Facilities that manufacture, import, process, or otherwise use listed toxic chemicals and are required to report annually their releases of those chemicals to any environmental media 1. Stormwater controls in areas where Section 313 water priority chemicals are stored, processed or otherwise handled. 2. Secondary containment for the entire capacity of largest single container or tank plus sufficient freeboard to allow for precipitation (25-year, 24-hour storm event), 3. Managed operations where Section 313 water priority chemicals are transferred, processed, or otherwise handled 4. Annual Certification by a Registered Professional Engineer
77 PPC Plan - References PADEP Guidelines for the Development and Implementation of Environmental Emergency Response Plans Document ID ; August 6, 2005 PADEP PAG-03 Authorization To Discharge Under The National Pollutant Discharge Elimination System (NPDES) General Permit For Discharges Of Stormwater Associated With Industrial Activities 3800-PM-WSFR0083d Rev. 12/2010
78 Emergency Planning and Community Right-to-Know Act (EPCRA) On December 4, 1984, methyl isocyanate, an extremely toxic chemical escaped from a Union Carbide chemical plant in Bhopal, India. Thousands died and many more were injured. Approximately six months later, a similar but less severe chemical release incident occurred at a facility located in Institute, West Virginia. These two events raised concern about local preparedness for chemical emergencies and the availability of information on hazardous chemicals. In response to these concerns, Congress passed the Emergency Planning and Community Right-to-Know Act (EPCRA) in 1986.
79 EPCRA Program Areas EPCRA has four major provisions: Emergency Planning (Sections ) Emergency Release Notification (Section 304) Hazardous Chemical Storage Reporting Requirements (Sections ) Toxic Chemical Release Inventory (Section 313)
80 EPCRA Sections Emergency Response Plans (Sections ) Emergency Response plans contain information that community officials can use at the time of a chemical accident. Any facility that has EHS at or above its threshold planning quantity must notify the State Emergency Response Commission (SERC) or the Tribal Emergency Response Commission (TERC) and Local Emergency Planning Committee (LEPC) within 60 days after they first receive a shipment or produce the substance on site.
81 EPCRA Section 304 Emergency Notification Requirements (Section 304) Facilities must immediately notify the LEPC and the SERC or the TERC if there is a release into the environment of a hazardous substance that is equal to or exceeds the minimum reportable quantity set in the regulations. This requirement covers the 355 extremely hazardous substances, as well as the more than 700 hazardous substances subject to the emergency notification requirements under CERCLA section 103(a)(40 CFR 302.4).
82 EPCRA Section 304 This emergency notification needs to include: The chemical name; An indication of whether it is an extremely hazardous substance; An estimate of the quantity released into the environment; The time and duration of the release; Whether the release occurred into air, water, and/or land; Any known or anticipated acute or chronic health risks associated with the emergency, and where necessary, advice regarding medical attention for exposed individuals; Proper precautions, such as evacuation or sheltering in place; and, Name and telephone number of contact person. A written follow-up written notice must also be submitted.
83 EPCRA Sections Community Right-to-know Requirements (Sections 311 and 312) Under Occupational Safety and Health Administration (OSHA) regulations, employers must maintain a material safety data sheet (MSDS) for any hazardous chemicals stored or used in the work place. Approximately 500,000 products are required to have MSDSs. Section 311 requires facilities that have MSDSs for chemicals held above certain threshold quantities to submit either copies of their MSDSs or a list of these chemicals to the SERC or TERC, LEPC, and local fire department.
84 EPCRA Sections Section 311(e) of EPCRA excludes the following substances: 1) Any food, food additive, color additive, drug, or cosmetic regulated by the Food and Drug Administration; 2) Any substance present as a solid in any manufactured item to the extent exposure to the substance does not occur under normal conditions of use; 3) Any substance to the extent it is used for personal, family, or household purposes, or is present in the same form and concentration as a product packaged for distribution and use by the general public; 4) Any substance to the extent it is used in a research laboratory or a hospital or other medical facility under the direct supervision of a technically qualified individual; and 5) Any substance to the extent it is used in routine agricultural operations or is a fertilizer held for sale by a retailer to the ultimate customer.
85 EPCRA Sections If the facility owner or operator chooses to submit a list of chemicals, the list must include the chemical or common name of each substance and must identify the applicable hazard categories. These hazard categories are: Immediate (acute) health hazard Delayed (chronic) health hazard Fire hazard Sudden release of pressure hazard Reactive hazard
86 EPCRA Sections If a list is submitted, the facility must submit a copy of the MSDSs for any chemical on the list upon request by the LEPC. Facilities that start using a hazardous chemical or increase the quantity to exceed the thresholds must submit MSDSs or a list of MSDSs chemicals within three months after they become covered. Facilities must provide a revised MSDS to update the original MSDS or list if significant new information is discovered about the hazardous chemical.
87 EPCRA Sections Facilities covered by section 311 must submit annually an Emergency and Hazardous Chemical Inventory Form to the LEPC, the SERC or the TERC, and the local fire department as required under section 312. Facilities provide either a Tier I or Tier II inventory form. Tier I inventory form include the following aggregate information for each applicable hazard category: An estimate (in ranges) of the maximum amount of hazardous chemicals for each category present at the facility at any time during the preceding calendar year; An estimate (in ranges) of the average daily amount of hazardous chemicals in each category; and, The general location of hazardous chemicals in each category.
88 EPCRA Sections The Tier II inventory form contains basically the same information as the Tier I, but it must list the specific chemicals. Tier II inventory form provide the following information for each chemical: The chemical name or the common name as indicated on the MSDS; An estimate (in ranges) of the maximum amount of the chemical present at any time during the preceding calendar year and the average daily amount; A brief description of the manner of storage of the chemical; The location of the chemical at the facility; and An indication of whether the owner elects to withhold location information from disclosure to the public. Many states (such as Pennsylvania) require completion of the Tier II inventory form. Section 312 information must be submitted on or before March 1 each year for information on chemicals present at the facility in the previous year.
89 EPCRA Sections 313 Toxics Release Inventory (Section 313) Section 313 of EPCRA established the Toxics Release Inventory. TRI tracks the management of certain toxic chemicals that pose a threat to human health and the environment. Facilities in different industry sectors must annually report how much of each chemical they managed through recycling, energy recovery, treatment and environmental releases. TRI reporting forms must be submitted to EPA and the appropriate state or tribe by July 1 of each year. These forms cover environmental releases and other management of toxic chemicals that occurred during the previous calendar year.
90 EPCRA Sections 313 The information submitted by facilities is compiled in the Toxics Release Inventory and made available to the public through the TRI website: TRI includes information about: On-site releases (including disposal) of toxic chemicals to air, surface water and land On-site recycling, treatment and energy recovery associated with TRI chemicals Off-site transfers of toxic chemicals from TRI facilities to other locations Pollution prevention activities at facilities Releases of lead, mercury, dioxin and other persistent, bioaccumulative and toxic (PBT) chemicals Facilities in a variety of industry sectors (including manufacturing, metal mining and electric power generation) and some federal facilities
91 EPCRA Reporting Timetables Reporting Schedules for EPCRA Section Numbers: 302 One time notification to SERC / TERC and LEPC 304 Each time a release above a reportable quantity of an EHS or CERCLA Hazardous Substance occurs to LEPC and SERC or TERC 311 One time submission of MSDS or list of hazardous chemicals. An update is required for new chemicals or new information about chemicals already submitted to the SERC or TERC, LEPC, and the fire department with jurisdiction over the facility 312 Annually, by March 1 to SERC or TERC, LEPC, and the fire department with jurisdiction over the facility 313 Annually, by July 1, to EPA, states and tribes
92 EPCRA References EPA EPCRA Webpage EPA EPCRA TRI Webpage EPA EPCRA Fact Sheet Electronic Code of Federal Regulations 40 CFR
93 TOXIC SUBSTANCES CONTROL ACT (TSCA) Premanufacture Notice This section briefly touches on a few areas of TSCA of potential interest to manufacturers: Mandated by section 5 of the TSCA, EPA's New Chemicals program helps manage the potential risk to human health and the environment from chemicals new to the marketplace. The program functions as a "gatekeeper" that can identify conditions, up to and including a ban on production, to be placed on the use of a new chemical before it is entered into commerce. Section 5 of TSCA requires anyone who plans to manufacture (including import) a new chemical substance for a nonexempt commercial purpose to provide EPA with notice before initiating the activity. This premanufacture notice, or PMN, must be submitted at least 90 days prior to the manufacture of the chemical. A PMN includes information such as specific chemical identity, use, anticipated production volume, exposure and release information, and existing available test data.
94 TSCA Chemical Data Reporting (CDR) Next CDR Reporting in 2016 The submission period for the 2016 CDR will be from June 1, 2016, to September 30, The CDR rule requires manufacturers, including importers of certain chemical substances included on the TSCA Chemical Substance Inventory, to report information on chemicals manufactured (including imported) in volumes of 25,000 lbs. or more at their site during any calendar year since Manufacturers (including importers) need to report production volume information for calendar years 2012, 2013, 2014, and While submitters will not report to EPA until 2016, they should start keeping track of their production volumes for these four years. For the 2016 CDR, the principal reporting year will be calendar year Full manufacturing, processing, and use information will be required only for 2015.
95 TSCA - Chemical Data Reporting Below are the requirements for the 2016 CDR: Manufacturers (including importers) will be required to report if, for any calendar year since 2011, a chemical substance was manufactured (including imported) at a site in production volumes of 25,000 lbs. or greater. The reporting threshold for processing and use information will be 25,000 lbs. Note: This is lower than the 100,000 lb threshold for processing and use information required for the 2012 CDR. The reporting threshold will be 2,500 lbs. for chemical substances that are: o Subject of a rule proposed or promulgated under TSCA section 5(a)(2), 5(b)(4), or 6 o Subject of an order issued under TSCA section 5(e) or 5(f) o Subject of relief that has been granted under a civil action under TSCA section 5 or 7
96 TSCA - Polychlorinated Biphenyls (PCBs) PCBs belong to a broad family of man-made organic chemicals known as chlorinated hydrocarbons. PCBs were domestically manufactured from 1929 until their manufacture was banned in They have a range of toxicity and vary in consistency from thin, light-colored liquids to yellow or black waxy solids. Due to their non-flammability, chemical stability, high boiling point, and electrical insulating properties, PCBs were used in hundreds of industrial and commercial applications including electrical, heat transfer, and hydraulic equipment; as plasticizers in paints, plastics, and rubber products; in pigments, dyes, and carbonless copy paper; and many other industrial applications.
97 TSCA - Polychlorinated Biphenyls PCBs may be present in products and materials produced before the 1979 PCB ban. Example products that may contain PCBs include: Transformers and capacitors Other electrical equipment including voltage regulators, switches, bushings, and electromagnets Oil used in motors and hydraulic systems Old electrical devices or appliances containing PCB capacitors Fluorescent light ballasts Cable insulation Oil-based paint Caulking
98 TSCA - Polychlorinated Biphenyls Authorized Uses of PCBs are described in 40 Code of Federal Regulations Part The authorized uses also provide various requirements (e.g. various inspections and recordkeeping) Marking Requirements for PCBs and PCB Items Each of the following PCB Items must be marked with the mark ML: (1) PCB containers; (2) PCB Transformers; (3) Large High-Voltage Capacitors; (4) Large Low-Voltage Capacitors; (5) PCB Large Low Voltage Capacitors at the time of removal from use; (6) Electric motors using PCB coolants; (7) Hydraulic systems; (8) Heat transfer systems; (9) PCB Article Containers containing articles or equipment; (10) Each storage area used to store PCBs and PCB Items for disposal.
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