1) Define a generator (40 CFR 260.10) subject to hazardous waste regulations.
2) List each category of generator based on amount of waste generated monthly. Include monthly quantities allowed per category, time limits, and storage requirements. Explain why choosing the correct generator status could be important to a company.
3) Shippers of HW must follow the regulations as outlined in RCRA and also in which law? List the law by name and give the regulatory citation to reference when determining proper shipping name.
4) Proper classification under the above requirements includes determining the following: (all elements required in basic shipping description)
5) What is required for mixtures or solutions of HW and non-hazardous waste for a proper shipping name? Give all conditions that must be met.
6) If you see a placard on a transport vehicle that is Class 3, what kind of material is being transported? Could you safely ship a Class 5 waste with this material? Explain why or why not.
7) Completely define the TSD aspect of a TSDF. (i.e. What does TSD stand for/define each?)
8) What records are required to be maintained by a TSDF? Be specific.
9) List 5 types of HW management units. Briefly describe each unit and some general operating requirements for each.
10) Compare and contrast the difference between an interim status TSDF permit and a full permit. Be specific.
11) Describe the requirements for both TSDFs and generators under Land Disposal Restriction regulations. What amendments provided these requirements (cite the law)?
12) Describe the RCRA corrective action process in detail. These actions are specific to certain facilities and releases. What type of clean up action is regulated by RCRA corrective actions and what type of facility?
13) Name the 5 federal laws that address/require spill reporting and describe the requirements for each law.
14) Describe liability under CERCLA. Include types of liability, entities that are potentially responsible, limits, and possible defences under CERCLA.
15) Thoroughly describe the RI/FS process under CERCLA.
16) Outline and describe the public's participation role in RCRA and CERCLA processes.
1) A generator is any site or person whose act or process produces a hazardous waste and is identified or listed in the section 261 of the 40 CFR 260.10 of EPA regulations. It also means any act that causes a hazardous waste and needs to be regulated.
2) Hazardous waste generators are divided into three categories:
i) Large quantity generators or LQG- These are generators who generates 1000 kilograms or more of acutely hazardous waste per month. Generators who produce 100kg or more of acute spill residue or soil per month are also termed as LQGs. They can accumulate waste only for 90 days on site barring certain exceptions. There must be at least one employee available to respond to emergencies usually it is the emergency coordinator. They must have detailed and written contingency plans on how to respond during emergencies. They must comply fully for the management of their tanks, drip pads, containers or containment buildings.
ii) Small Quantity Generators or SQG - Generators who generate more that 100 kg but less than 1000 kg of hazardous waste per month are termed SQG. They can accumulate waste on the site for upto 180 days without a permit or if the shipping distance is more than 200 miles then upto 270 days. The quantity of hazardous waste on the site cannot exceed 6000 kg. There must be atleast one employee available to respond to emergencies usually it is the emergency coordinator. They do not require any specific detailed contingency plans for emergencies. Their storage requirements are basic with technical standards for tanks and containers.
iii) Conditionally exempt small quantity generators or CESQ- These generators generate 100kgs or less of hazardous waste per month or 1kg or less of acutely hazardous waste. CESQs are required to identify all the types of hazardous waste generated. They cannot acquire more than 1000kgs of waste at any given time. They are required to deliver the hazardous wastes to a facility or person who has the authority to manage it. They have no specific storage requirements.
Companies should be careful when choosing their generator status as the safety of the company; employees and the community are dependent on it. If they estimate is less than the quantity of actual HW generated then they end up polluting the environment and go against EPA regulations.
3) The law that must be followed while determining proper shipping name is the RCRA or Resource Conservation and Recovery Act. The regulatory citation that needs to be referenced for proper shipping name is 49CFR 172.101 and a hazardous waste manifest form needs to completed along with the given EPA identification number.
4) Shipping of hazardous materials must include the basic description of the hazardous material which includes the identification number, hazard class, the proper shipping class and name of the packing group whenever applicable. In addition subsidiary information may include information like technical names of the hazardous material, quantity of material, the number and type of packages and those that come under part 172.201 to 172.204 of the guidelines of shipping of hazardous material. The emergency contacts must also be listed.
5) A mixture or solution not identified specifically by name, comprised of a single predominant hazardous material identified in the Hazardous Material Table must be described using ...
Waste Management and Pollution Control
1) PCBs are regulated under which law? List PCB classifications with concentrations.
2) Describe the disposal requirements for transformers, capacitors, containers, and liquids. Is manifesting required for PCB disposal?
3) Detail the spill reporting requirements for PCB spills.
4) Which law studied this term is the most burdensome to environmental managers and why?
Use the following scenario to answer questions 5, 6, and 7. Give detailed answers.
Fabricating printed wiring boards (PWB) involves a variety of different processes that are
divided into two categories: dry and wet fabrication. Dry fabrication is composed of drilling,
routing, and imaging; whereas wet fabrication is composed of scrubbing, developing, plating,
and etching. This study focuses only on the wet processes and the associated problems relative to
environmental stewardship. This shop had much to learn about environmental responsibility and natural resource conservation. The past processes of the shop were not a deliberate "nose-thumbing" attitude toward the environment and natural resources; but rather it was brought about by lack of knowledge and awareness. All of the chemicals involved in wet processing are hazardous to some degree. These hazards revolve around the properties of the chemicals. For example, strong mineral acids are extremely corrosive and the vapors readily degrade most metals on contact. Inhalation of these vapors can cause a range of problems such as slight respiratory irritation, pulmonary edema, and death. All these hazards can be reduced or even eliminated from the work place by engineering and administrative controls. Engineering controls include proper ventilation and material substitution. Administrative controls include Standard Operating Procedures (SOP) and training. Personal protective equipment (PPE) is used when the hazard hasn't been eliminated from the workplace.
Past Operation Practices
The processes of environmental concern were electroless copper deposition, electrolytic copper
plating, and electrolytic tin/lead or solder plating. All of the plating shop rinses consisted of tap
water overflow that were discharged directly into an Industrial Sewer System (ISS). The initial
processing flow rates were approximately 2,000 gallons/hour. Contained within this substantial
rinse discharge were regulated materials (i.e., copper, tin, lead, and formaldehyde).
Scrubbing and deburring equipment used to process PWB panels was plumbed to discharge
directly into the ISS. This discharge was approximately 12 gallons/minute and contained copper
particles along with fibrous material from the scrubber wheels.
The photoresist developer and stripper used in the imaging process were also plumbed to
discharge directly into the ISS with approximately 6 gallons/minute of outflow. Alkaline effluent
in the imaging process contained residual organic material in solution and suspended particles.
Temperature control was a critical parameter in many of the steps involved in fabricating PWBs.
Maintaining predetermined temperature parameters was accomplished with tap water circulation.
All of the cooling water was discharged into the ISS. There were no recycling steps practiced.
The etchers, developer, lamination press, and vapor degreasers required tap water cooling to
control the temperature. During normal operations, approximately 8,000 gallons of noncontact
cooling water was used weekly. (Water usage fluctuated depending on the temperature of the
Materials used in the wet fabrication processes are hazardous. The chemicals employed can be
categorized into three groups: oxidizers, corrosives, and toxins.
1. Oxidizers are materials that readily oxidize substances with which they come into contact. An example is chlorine gas, which was used to regenerate an etching system. The etchant was chemically reduced as copper was removed from the PWB panel. Chlorine gas was used to reoxidize the etchant and restore etching ability.
2. Corrosive materials include acids, bases, and halogens. Each of these materials could cause corrosion on substances with which they come into contact. (An example of this is the effect that strong mineral acid vapors have on metals and respiratory systems.)
3. Toxins include toxic materials, irritants, carcinogens, and asphyxiants. These materials are known to have an adverse effect on humans. Most of the chemicals used in the fabrication of PWBs possessed one or more of these undesirable properties. Since there was a great concern for protecting the personnel exposed to these substances, it was extremely important that the PPE be properly used. The solution employed to etch copper without destroying the tin/lead plated pattern was chrome trioxide and sulfuric acid. The etching solution was heated to 120oF in a conveyorized spray module and was used until spent. Waste products were then transferred into drums, labeled, manifested, and sent to waste disposal. (The main component, chrome trioxide, is a known carcinogen and exposure to this compound has been documented to cause lung cancer.)
The solvent used to remove dryfilm photoresist was methylene chloride, a suspected carcinogen.
Removal was accomplished by placing a large solvent-resistant tray in an open sink and adding
solvent. A number of panels were then placed in the solution and allowed to soak for several
minutes. During this dwell time, the photoresist blistered and floated free of the panel surface.
The panels were then withdrawn from the tray and held under running water to rinse the residual
solvent into the Domestic Sewer System (DSS). A liquid photoimagable resist was used to fabricate fine line circuitry. This resist was a xylenebased material formulated with hotosensitive compounds. The resist was applied by pumping the compound onto a set of rollers which, in turn, was deposited onto the panels being processed. After each use, the equipment had to be cleaned by wiping the soiled areas with xylene. (Xylene is a chemical suspected of damaging bone marrow, thus causing anemia.).
As California was experiencing a 7-year drought a hard look was taken into operation practices.
5) Describe how you would manage this waste stream. Be specific in approaches and include personnel aspects. What law regulates this material?
6) Describe some waste minimization techniques that could be used for this waste stream. Keep in mind that water is scarce.
7) What HW characteristics do the materials used in this process have?