hazardous waste transportation 1/ 58 © copyright training 4 today 2001 published by envirowin...

Hazardous Waste Transportation 1/ 58 © Copyright Training 4 Today 2001 Published by EnviroWin Software LLC

WELCOME

HAZARDOUS WASTE TRANSPORTATION

CUSTOMIZED ENVIRONMENTAL TRAINING


INSTRUCTOR

Insert Instructor Name Here


Discuss the EPA ID Number Requirements for Transporters. Discuss Packaging, Labeling, Marking and Placarding

Requirements for Transporters. Discuss Compliance With the Hazardous Waste Manifest. Discuss the Transporter’s Responsibilities if a Hazardous

Waste Discharge Occurs. Discuss the Manifest Requirements for Different Modes of

Transportation. Discuss Transfer Facilities Responsibilities. Discuss Transporter Training Requirements. Discuss Reports and Recordkeeping. Recommend Inspection Items.

OBJECTIVES


Understand the EPA ID Number Requirements for Transporters.

Be Familiar With the Packaging, Labeling, Marking and Placarding Requirements for Transporters.

Understand Compliance With the Hazardous Waste Manifest.

Understand the Transporter’s Responsibilities if a Hazardous Waste Discharge Occurs.

Understand the Manifest Requirements for Different Modes of Transportation.

Understand Transfer Facilities Responsibilities.

Understand Transporter Training Requirements.

Understand Reports and Recordkeeping Requirements.

GOALS


BACKGROUND

In 1998, 61,234 industries reported a total of 7.3 billion pounds of hazardous chemicals released to the air, land and water in the United States.

The Department of Transportation annually issues over 500 warning letters, 100 tickets, 1,400 penalties and collects over $7 million in total penalties for non-compliance of hazardous waste transportation requirements.


Supervisors

Facility Engineers

Maintenance Personnel

Department Managers

Building Occupants

Process Specialists

Environmental and Safety Committees

LEARNERS


The goal of this course is to provide supervisors with the tools needed to safely transport hazardous waste and remain in compliance. It recommends practical, actions that can be carried out by facility management, maintenance personnel and building occupants. The course will help you integrate good hazardous waste transportation management activities into your existing organization and identify which of your staff have the necessary skills to carry out those activities.

OVERVIEW


WHAT THIS COURSE DOES NOT DO

The course is not intended to provide information detailed information on packaging, labeling, and placarding of each hazardous waste. Nor is it specific training for hazardous waste spills and cleanup. These specialties required training beyond the intended scope of this course. Where this expertise is needed, outside assistance should be solicited.


RESOURCE CONSERVATION AND RECOVERY ACT (RCRA)

RCRA addresses the management of hazardous waste and the transportation of hazardous waste


FEDERAL REGULATIONS

Pertinent Regulations:

40 CFR 263 – Standards Applicable to Transporters of Hazardous Waste

40 CFR 262 – Standards Applicable to Generators of Hazardous Waste

49 CFR 100-185 – Department of Transportation Hazardous Materials Regulations


OVERVIEW

EPA has promulgated regulations governing the safe transport of hazardous wastes from generator to designated facility Section 263 applies to carriers transporting hazardous waste within the United States when that waste is subject to the manifesting requirements of Section 262 Transportation means "the movement of hazardous waste by air, rail, highway, or water” EPA promulgated the transporter requirements to be consistent with appropriate DOT regulations In general, transporters of hazardous waste must comply with the requirements of Part 263, as well as the specific DOT requirements


OVERVIEW

DOT has incorporated RCRA hazardous wastes as one of the types of hazardous materials that must be transported according to DOT specifications The Joint Uniform Hazardous Waste Manifest serves as both the EPA tracking form and the shipping paper required under DOT This system allows the in-transit management of hazardous waste to be regulated safely and efficiently while allowing both EPA and DOT to retain enforcement of their respective regulations


OVERVIEW

EPA regulates the off-site transportation of hazardous wastes Part 263 does not apply to the on-site movement of wastes within a facility's boundary The term on-site includes the transport of hazardous waste between contiguous properties, even when separated by a public road "provided that the entrance and exit between the properties in at a crossroads intersection, and access is by crossing, as opposed to going along, the right-of-way" Generally Part 263 does not apply to transportation of shipments that do not require a manifest


DEFINITIONS

Transport vehicle means a motor vehicle or rail car used for the transportation of cargo by any mode Each cargo-carrying body (trailer, railroad freight car, etc.) is a separate transport vehicle Transportation means the movement of hazardous waste by air, rail, highway, or water Transporter means a person engaged in the offsite transportation of hazardous waste by air, rail, highway, or water


EPA IDENTIFICATION NUMBER

A transporter is required to obtain an EPA ID number before transporting hazardous waste Transporters obtain EPA ID numbers by completing and submitting EPA’s form the Notification of Regulated Waste Activity EPA issues transporter ID numbers for primary offices or places of business, not individual transporting terminals


PACKAGING

According to DOT’s 49 CFR 171.2(a), anyone who offers or accepts a hazardous material shipment must comply with the Hazardous Materials Regulations (HMR) No person, individual or company may offer or accept a hazardous material for transportation in commerce unless the shipment complies with the HMR The shipper and the carrier share in the responsibility to offer and/or accept only hazardous materials that comply with the HMR


PACKAGING

Preparation of hazardous materials for transportation is the responsibility of the person who offers the material for transportationUnless otherwise provided, a hazardous material may be offered for transportation in an approved packaging or container only if the material is: properly classed, properly described, in a properly manufactured and tested packaging, in a packaging marked in accordance with the HMR, the package fully complies with 49 CFR Part 173, 178, and 179


LABELING

Before transporting or offering hazardous waste for transportation off-site, a generator must label each package in accordance with the applicable Department of Transportation regulations on hazardous materials under 49 CFR part 172


MARKING

Before transporting or offering hazardous waste for transportation off-site, a generator must mark each package of hazardous waste Before transporting hazardous waste or offering hazardous waste for transportation off-site, a generator must mark each container of 110 gallons or less used in such transportation with the following words:HAZARDOUS WASTE—Federal Law Prohibits Improper Disposal. If found, contact the nearest police or public safety authority or the U.S. Environmental Protection Agency.Generator’s Name and Address ___________.Manifest Document Number ____________.


PLACARDING

Before transporting hazardous waste or offering hazardous waste for transportation off-site, a generator must placard or offer the initial transporter the appropriate placards according to Department of Transportation regulations for hazardous materials under 49 CFR part 172, subpart F


COMPLIANCE WITH THE MANIFEST

EPA created a tracking mechanism to ensure that hazardous waste sent to a treatment, storage, and disposal facility (TSDF) reaches its destination The manifest is the central element of this system. The Uniform Hazardous Waste Manifest (EPA Form 8700-22) and its instructions are found in the appendix to 40 CFR Part 262 The manifest is the control and transport document that accompanies the waste during transport from its generation site to its final destination facility


COMPLIANCE WITH THE MANIFEST

40 CFR Part 263, Subpart B, dictates transporter responsibilities for the manifest system Before hazardous waste can be transported, the transporter must sign and date the manifest The transporter must then deliver the hazardous waste shipment to the next transporter, the designated facility, or the alternate facility listed on the manifest If the waste cannot be delivered to the designated receiver, the generator must be contacted for further instructions, and the manifest must be revised accordingly The manifesting responsibilities vary depending on the mode of transportation


HAZARDOUS WASTE DISCHARGES

If a transporter discharges or spills hazardous waste, he or she is required to take immediate action to protect human health and the environment "Immediate action" is not specifically defined, however, it may include containing the spill, notifying local authorities, and notifying the National Response Center as required by DOT or Superfund regulations DOT may require a written report Federal, state, or local authorities may require a transporter to take actions in response to a discharge or spill if the discharge is determined to present a long-term hazard to human health or the environment


DISCHARGE CLEANUP

A transporter must clean up any hazardous waste discharge that occurs during transportation or take such action as may be required or approved by Federal, State, or local officials so that the hazardous waste discharge no longer presents a hazard to human health or the environment


MODES OF TRANSPORTATION

Transportation of hazardous waste from the generator to the designated facility can be accomplished by several means of transportation The regulations establish guidelines for the proper handling and recordkeeping of hazardous waste transported by highway, water, rail, or air


HIGHWAY SHIPMENTS

Highway transporters must complete the following manifest and recordkeeping requirements: Sign and date the manifest Leave a signed and dated copy of the manifest with the generator Ensure that the manifest accompanies the waste Obtain the dated signature of the next transporter or the owner/operator of the designated facility, and Keep a copy of the manifest for at least three years


WATER (BULK) SHIPMENTS

Water transporters must comply with the directions on the manifest, obtain an EPA ID number, and be listed on the manifest When shipping hazardous waste by water, however, the manifest is not required to physically accompany the shipment Instead, the person delivering the waste to the initial water transporter obtains the date of delivery and signature of the water transporter on the manifest and forwards it to the designated facility


WATER (BULK) SHIPMENTS

In addition, if the waste is delivered directly to the TSDF, the water transporter must: Ensure that a shipping paper (e.g., waybill), containing the same information as the manifest, accompanies the waste Obtain the dated signature of the owner or operator of the designated facility on the shipping paper or the manifest Sign and date the manifest Retain a copy of the shipping paper or manifest for three years


RAIL SHIPMENTS

As with the other methods of transport, rail transporters must have an EPA ID number and ensure the designated facility is listed on the manifest Similar to water shipments, rail transporters must comply with the directions on the manifest and must be listed as a transporter on the manifest, but the actual manifest form does not have to accompany the waste shipments at all times Instead, a standard waybill or other shipping document containing all the manifest information except EPA ID number, generator certification, and signatures may accompany the waste


RAIL SHIPMENTS

Initial rail transporter's duties include: Signing and dating the manifest Returning a signed copy of the manifest to the non-rail transporter Retaining a copy of the manifest and rail shipping paper for three years Forwarding at least three copies to the next non-rail transporter or designated facility (if the shipment is delivered by rail), or the last rail transporter designated to handle the waste in the United States


RAIL TO TSDF

For rail delivery to the designated facility, the rail transporter must obtain the dated signature of the owner or operator of the designated facility on the manifest or shipping paper, and retain one copy of the manifest or shipping paper for three years


RAIL TO NON-RAIL

For delivery by rail to a non-rail transporter, the rail transporter must obtain the dated signature of the non-rail transporter on the manifest and must retain a copy for at least three years Since the manifest is not required to accompany the rail shipment, the non-rail transporters might obtain a copy of the manifest directly from the generator If the hazardous waste is leaving the United States, the transporter must receive an Acknowledgment of Consent from the generator, and ensure that it accompanies the shipment at all times The Acknowledgment of Consent is consent from the receiving country to accept the shipment


PIPELINE SHIPMENTS

Transportation of hazardous waste by pipeline does not meet the RCRA definition of transportation Piping as a mode of transport is not specifically addressed by RCRA, nor is it prohibited However, hazardous waste piped off-site may be subject to other provisions of RCRA


TRANSFER FACILITIES

A transfer facility is an area used to temporarily store wastes on route to a TSDF Transfer facilities may be carrier terminals, loading docks, or other areas where waste is kept during the normal course of transportation Transporters may store manifested shipments of hazardous waste in containers at a transfer facility for 10 days or less without a storage permit under Section 263.12


TRANSFER FACILITIES

Transfer facilities are not required to operate under RCRA storage permits provided the waste is manifested, kept in DOT specification containers, and stored less than 10 days There is no specific time limit for a hazardous waste shipment to reach the designated facility. If a LQG does not receive a signed copy of the manifest from the designated facility within 35 days of the date the initial transporter accepted the waste, the generator must contact the transporter If a copy of the manifest is not received within 45 days of the date the waste was accepted by the initial transporter, then the LQG must submit an Exception Report to the EPA Regional Administrator


EXPORTING HAZARDOUS WASTE

There are additional requirements for transporters who export hazardous waste Before waste can be exported to a foreign country, the generator (or primary exporter) must obtain the country's approval for the shipment via an acknowledgment of Consent that is processed by the State Department The regulations governing exports of hazardous waste are found in Part 262, Subpart E


TRANSPORTER AS A GENERATOR

Anyone, including a transporter, who imports hazardous waste from a foreign country must comply with the generator requirements, including initiating a manifest If the transporter mixes wastes with different DOT shipping descriptions by placing them in a single container, the transporter must initiate a new manifest and comply with the generator regulations The transporter should be named in the generator block and the old manifest(s) should still accompany the waste Additionally, any other substantial shipping changes would require that a new manifest be prepared


PERMITS, LICENSES, AND INSURANCE

Transporters do not need RCRA permits if they comply with 40 CFR Part 263 If the transporter stores hazardous waste longer than 10 days or treats or disposes of wastes at their facility, a RCRA permit would be required In addition, states often require special permits or licenses for transporters Although EPA does not require transporters to have liability insurance, the Federal Motor Carrier Act, implemented by DOT, does require it


EPA/DOT INTERFACE

As part of the RCRA cradle-to-grave waste management system, the transporter regulations ensure proper delivery of the hazardous waste to the designated TSDF The 40 CFR Part 263 transporter requirements adopted portions of the DOT regulations for the safe transport of DOT classified hazardous materials The DOT references in the RCRA regulations include requirements for labeling, marking, placarding, and containers, and also outline the DOT requirements for responding to spills or discharges EPA incorporated these requirements by reference, to ensure consistency with the DOT regulations and to avoid duplicative and burdensome requirements


TRANSPORTER TRAINING

DOT’s Hazardous Materials Regulations (HMR) include training requirements in several sections for Hazardous Waste Transporters: GENERAL: 49 CFR 173.1 SPECIFIC: 49 CFR 172.704 MODAL: Air 49 CFR 175.20; Vessel 49 CFR 176.13; Highway 49 CFR 177.800 and 177.816



TRAINING REQUIREMENTS

Each hazmat employer must: train and test, certify, and develop and retain records of current training (inclusive of preceding three years) for each hazmat employee (during the period of employment and 90 days thereafter)



Hazmat training must include: General awareness/familiarization, Function-specific, Safety, and Driver training (for each hazmat employee who will operate a motor vehicle).



Initial training A new employee, or an employee who changes job functions, may perform hazmat job functions before completing training, provided: - the employee does so under the direct supervision of a properly trained and knowledgeable hazmat employee- the hazmat training is completed within 90 days of employment or change in job function Recurrent training Required at least once every three years Relevant training received from a previous employer or source may be used to satisfy the requirements



Training Records must include: Hazmat employee's name; Completion date of most recent training; Training Materials (Copy, description, or location); Name and address of hazmat trainer; and Certification that the hazmat employee has been trained and tested


RECORDKEEPING

A generator must keep a copy of each manifest 3 years or until he receives a signed copy from the designated facility which received the waste This signed copy must be retained as a record for at least three years from the date the waste was accepted by the initial transporter A generator must keep a copy of each Biennial Report and Exception Report for a period of at least three years from the due date of the report A generator must keep records of any test results, waste analyses, or other determinations made in accordance with 40 CFR 262.11 for at least three years


BIENNIEL REPORT

A generator who ships any hazardous waste off-site to a TSDF within the U.S. must prepare and submit a single copy of a Biennial Report to the Regional EPA Administrator by March 1of each even numbered year The Biennial Report must include the following information:(1) The EPA identification number, name, and address of the generator;(2) The calendar year covered by the report;(3) The EPA identification number, name, and address for each off-site TSDF;(4) The name and EPA identification number of each transporter


BIENNIEL REPORT

(5) A description, EPA hazardous waste number, DOT hazard class, and quantity of each hazardous waste shipped off-site for shipments to a TSDF(6) A description of the efforts undertaken to reduce the volume and toxicity of waste generated(7) A description of the changes in volume and toxicity of waste actually achieved during the year in comparison to previous years (8) The certification signed by the generator or authorized representative Any generator who treats, stores, or disposes of hazardous waste on-site must submit a biennial report


EXCEPTION REPORTING

A generator of greater than 1000 kilograms/month who does not receive a copy of the manifest with the handwritten signature of the owner or operator of the TSDF within 35 days of the date the waste was accepted by the initial transporter must contact the transporter and/or the owner or operator of the TSDF A generator of greater than 1000 kilograms/month must submit an Exception Report to the EPA Regional Administrator if he has not received a copy of the manifest with the handwritten signature of the owner or operator of the designated facility within 45 days of the date the waste was accepted by the initial transporter


EXCEPTION REPORTING

The Exception Report must include: A legible copy of the manifest for which the generator does not have confirmation of delivery; A cover letter signed by the generator or his authorized representative explaining the efforts taken to locate the hazardous waste A generator of greater than 100 kilograms but less than 1000 kilograms of hazardous waste/month who does not receive a copy of the manifest within 60 days of the date the waste was accepted by the initial transporter must submit a legible copy of the manifest, with some indication that the generator has not received confirmation of delivery, to the EPA Regional Administrator


RECOMMENDED INSPECTION ITEMS

Determine if the facility transports hazardous waste off-site by using their own vehicles or a contractor Verify that the transporter has an EPA identification number Verify that all waste accepted, transported, or offered for transport is accompanied by a manifest Verify that prior to transport, the transporter signs and dates the manifest and returns a copy to the generator prior to leaving the facility Verify that the transporter retains a copy of the manifest after delivery



Verify that all wastes accepted by the transporter are delivered to the designated facility listed on the manifest, or the alternate designated facility if an emergency prevents delivery, or the next designated transporter or the place outside the United States designated by the generator Verify that manifests are kept on file for three years



Determine what pre-transport procedures for hazardous waste are used Inspect a sample of containers awaiting transport to verify that containers are properly constructed and exhibit no leaks, corrosion, or bulges Examine end-seams for minor weeping that indicates drum failure Verify that labeling and marking on each container is compatible with the manifests



Verify that the following information is displayed on a random sample of containers of 110 gal. (416.40 L) or less in accordance with 49 CFR 172.304:

“HAZARDOUS WASTE - Federal Law Prohibits Improper Disposal. If found, contact the nearest police or public safety authority or the U.S. Environmental Protection Agency.”- Generator's name and address- Manifest Document Number ____ . Verify that proper DOT placarding is available for the transporter



Verify that transport operators have instructions to notify local authorities and take clean-up action so that the discharge does not present a hazard Verify that transporters give notice to the National Response Center and report in writing as required by 49 CFR 171.15 and 49 CFR 171.16



Determine if the facility has a transfer facility.

If so, verify the following:

- Transfer facility storage is for 10 days or less

- DOT packaging requirements are met

- Shipments are manifested and manifests accompany shipments

- Storage is consistent with good management practices Verify that transporters do not store manifested shipments of land disposal restricted wastes for more than 10 days


Remember, You Control Your Facility or Area!

Review Procedures With Them Before Starting the

Job!

Ensure They Are Properly Trained!

Determine Their Environmental Compliance Record!

Determine Who Is in Charge of Their People!

Determine How They Will Affect Your Facility’s

Environmental Compliance!

TIPS FOR USING CONTRACTORS


ELEMENTS OF A SUCCESSFUL HAZARDOUS WASTE TRANSPORTATION PROGRAM

1. DETAILED WRITTEN HAZARDOUS WASTE

TRANSPORTATION INSPECTION GUIDELINES.

2. DETAILED WRITTEN HAZARDOUS WASTE

TRANSPORTATION BEST MANAGEMENT PRACTICES.

3. EXTENSIVE EMPLOYEE TRAINING PROGRAMS

4. PERIODIC REINFORCEMENT OF TRAINING

5. SUFFICIENT DISCIPLINE REGARDING IMPLEMENTATION

6. PERIODIC FOLLOW-UP


THE IMPORTANCE OF A CLEAN ENVIRONMENT

“I would ask all of us to remember that protecting our environment is about protecting where we live and how we live. Let us join together to protect our health, our economy, and our communities -- so all of us and our children and our grandchildren can enjoy a healthy and a prosperous life.”

Carol Browner Former EPA Administrator

hazardous waste transportation 1/ 58 © copyright training 4 today 2001 published by envirowin...

Documents

hazardous waste manifest

hazardous waste discharge

copyright training

department of transportation

manifest requirements

pounds of hazardous

placarding requirements

recordkeeping requirements