1. RCRA: Resource Conservation & Recovery Act
Arizona Army National Guard
HAZARDOUS WASTE AWARENESS
Training Program
What RCRA training program is all about. H/W awareness training program presented by DEMA Environmental.

2. Course Objectives Definitions – solid and hazardous wastes
Understanding of RCRA
Definitions – solid and hazardous wastes
Identification of hazardous wastes (HW)
Management of HW
Classification of HW generators
Accumulation and inspections of HW
Management of containers
Disposal of HW
Emergencies
Best waste management practices and guidance. Course objectives.

3. What is RCRA? RCRA – Resource Conservation & Recovery Act:
Enacted in 1976 as an amendment to the Solid Waste Disposal Act
40 CFR Parts 260 – 273 regulates hazardous waste (HW)
State of Arizona and NGB enacted their own:
Arizona Administrative Code Title 18, Chapter 8
AR 200-1, Chapter 10 (December 2007 version)
The RCRA program comes from Congress and passed down to the States through NBG. AR 200-1, EPA and ADEQ
give this program reference and monitor work activities.

4. What is a RCRA Solid Waste?
RCRA defines solid waste as:
Garbage
Refuse
Sludge
Industrial wastes
Other discarded materials – solid, semi-solid, liquid or gaseous
RCRA defines solid waste as:
Garbage – milk cartons, coffee grounds
Refuse – metal scrap, wall board, empty containers
Sludges – from water supply treatment plants, waste treatment plants, pollution control equipment
Industrial wastes – Manufacturing process wastewaters and non-wastewater sludges and solids
Other discarded materials – solid, semi-solid, liquid, or gaseous
RCRA defines discarded solid wastes as:
Abandoned
Recycled
Inherently waste-like

5. Congressional Definition
Hazardous waste (HW) – solid waste, which because of its quantity, concentration, or physical, chemical, or infectious characteristics may:
Cause an increase in mortality or increase in serious irreversible illness
Pose a present or potential hazard to the environment or human health or when improperly managed
Hazardous waste (HW) is a solid waste, or combination or solid wastes, which because of its quantity, concentration, or physical, chemical, or infectious characteristics may:
Cause, or significantly contribute to, an increase in mortality or an increase in serious irreversible, or incapacitating reversible, illness
Pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, or disposed of, or otherwise managed.

6. Cradle-to-Grave Concept
HW regs are based on this concept, which makes the generator of the HW ultimately responsible.

7. What Kinds of Waste Do We Have?
Hazardous
Recyclables
Used Oil
Give examples of each kind of waste.
Medical Waste
Regulated Waste
Solid Waste

8. Why We Manage HW AZARNG committed to environmental compliance
Federal and State laws require proper HW management
Improper HW waste management can:
Adversely affect public health and the environment
Cause financial and criminal penalties to offenders

9. who handles or works with
Who Manages HW?
Everyone
who handles or works with
HAZARDOUS WASTE!

10. How Do We Manage HW? Comprehensive HW management includes:
Identification
Disposal of waste
Classification
Documentation
Accumulation
Education of personnel
Identify what waste streams are on site, characterize them, determine with they are hazardous or not. Place in proper container, label and mark correctly. Use SAP and CAA storage prior to disposal.

11. Who to Contact for HW Help
For HW compliance guidance and assistance, contact:
Pollution Prevention Dept – Environmental Office
Suzan Curtin – P2 Mgr –
Randy Dozer – Env Health Spec –
Kevin King – Haz Matl Spec –
Environmental Office
MAJ John Ladd – Env Program Mgr –
Mary Westdyke – Env Administrative Asst –

12. Identifying Hazardous Waste!
Must meet at least one of these criteria:
Listed by EPA
Has at least one of these HW characteristics: Ignitable Corrosive Reactive Toxic (TCLP)
Is a Universal Waste: Lamps Batteries
Pesticides Mercury-containing Equipment
Before we can start the management of HW, we need to identify exactly what we have. To do that, we turn to the regulations provided by EPA and ADEQ to assist us in our determination.
Must meet at least one of these criteria:
Listed by EPA
Has at least one of these HW characteristics: Ignitable, Corrosive, Reactive or Toxic (TCLP)
Is a Universal Waste: Lamps, Batteries, Pesticides, Mercury-containing Equipment

13. EPA’s Listed Wastes Listed hazardous wastes come from:
Generic industrial processes
Certain sectors of industry
Unused pure chemical products and formulations
List definitions:
P – acutely toxic, fatal to humans
U – toxic chemicals that display other characteristics
F – nonspecific sources
K – specific sources
Listed wastes come from:
Generic industrial processes
Certain sectors of industry
Unused pure chemical
These waste codes on entered on the waste manifest sheet to properly identify each waste source:
P – acutely toxic, fatal to humans
U – toxic chemicals that display other characteristics
F – nonspecific sources
K – specific sources
EPA always has option to list a HW if it has cause to believe that, for some other reason, the waste fits in with the statutory definition of HW developed by Congress.
EPA uses three criteria to list HW wastes:
Toxic Listed – contains toxic chemicals that can pose a threat to human health & the environment
Acute Hazardous – dangerous chemicals that can pose a threat to human health & the environment; fatal to humans & animals in low doses
Characteristic – exhibits one of four characteristics, which are ignitable, corrosive, reactive & toxic (not to be confused with Toxic Listed)
Listed wastes are identified with these letters:
F, K, P, U
F List: Wastes from nonspecific sources
K List: Wastes from specific sources
Pure or commercial formulations of specific unused chemicals apply to:
P List: Acutely toxic; fatal to humans
U List: Toxic chemicals that display other characteristics, such as ignitable or reactive
F List includes:
Spent solvent from processes such as mechanical repair, dry cleaning, degreasing and cleaning. (F005 – F005)
NOTE: This list applies only to those solvents that are used for their solvent properties and which can no longer be used without reprocessing; plus the solvent must meet the concentration provided in the description before use
Electroplating and other metal finishing wastes (F006 – F012 & F019)
Dioxin-bearing wastes, which allegedly are among the most dangerous chemicals, and for the list come from manufacturing processes of specific pesticides or chemicals used to make those pesticides; usually considered an acute HW (F020 – F023, F026 –F028)
Chlorinated aliphatic hydrocarbons production wastes; these chemicals are used to make vinyl chloride, which is the main ingredient of PVC (F024, F025)
Other F List wastes include wood preserving wastes, petroleum refinery wastewater treatment sludges and multisource leachate (leachate that accumulates at the bottom of a landfill)
K Lists
K Lists wastes are similar to F List wastes in that they manufacturing process wastes. First, one must check to see if the waste fits within 1 of 13 industrial categories, and then the waste must match one of the detailed K List descriptions.
Some examples of these industrial categories include wood preservation, manufacturing of organic chemicals, pesticides, petroleum, vet pharmaceuticals, inorganic chemicals, explosives, and iron and steel production.
P and U List wastes are from unused chemicals, generally these are either off-spec or recovered from a spill clean-up.
A P or U List waste must meet one of three criteria:
Be on the P or U list
The chemical in the waste must be unused
The chemical in the waste must be a commercial chemical product (CCP)
Definitions of a CCP include:
100% Pure
Technical grade
Sole active ingredient
NOTE: If a waste meets the definition of a listed waste, but does not exhibit that characteristic at the point of generation, then it is not a listed HW. For example, meets the definition of F003, but is not ignitable – then not HW

14. What Are HW Characteristics?
REACTIVE:
Violently reacts with H2O
IGNITABLE:
<140oF
D001
D003
HW characteristics are probably the most common way of determining if a waste is hazardous. This is also important if a waste meets the listed definition, but does not exhibit that particular characteristic (as we learned from the last slide).
The D numbers identify the hazardous waste on the HW Manifests as a waste with one or more HW characteristics.
Characteristic HW is any waste that exhibits measurable properties which indicates that a waste poses enough of a threat to warrant regulation. EPA tried to identify those characteristics, that when present, can cause death or injury to a human, or ecological damage. These characteristics can either be acute or chronic (long-term). Some of these wastes may have LDRs – Land Disposal Restrictions – placed on them, too.
Hence, the development of the 4 characteristic groups:
IGNITABLE – anything that has a flashpoint of <140F
Most of these wastes are liquid, but there are some solids, if they can catch fire spontaneously, through friction or adsorption of moisture under normal conditions, and burns so vigorously that it creates a hazard. Some compressed gasses also qualify as ignitable. Any waste meeting DOT’s definition of an oxidizer is an ignitable waste.
Ignitable wastes are the most common of all HW.
CORROSIVE – these HW are either acidic or alkaline (basic), and can corrode or dissolve flesh, metals or other materials.
Aqueous HW must either be above a pH of 12.5 or lower than a pH of 2; solid, non-aqueous wastes are not evaluated for corrositivity.
REACTIVE – these HS readily explode or undergo violent reactions or react to release of toxic gases or fumes
There are no accurate tests, so EPA uses a narrative to make a determination:
Explodes or reacts violently when exposed to water under normal conditions
Creates toxic fumes or gases at a hazardous level when exposed to water under normal conditions
Explodes if heated under confinement, or exposed to a strong igniting source, or meets the DOT classification as an explosive
Generates toxic levels of sulfide or cyanide gas when exposed to a pH range of 2.5 – 12.5
TOXICITY – this category is for those chemicals that would be harmful in leachate because of threats to the drinking water supplies
The TCLP (Toxicity Characteristic Leaching Procedure) was developed to determine if leaching would be a problem, and there are 40 chemicals from which to make a determination.
Some examples of metals include lead (5.0 mg/l), arsenic (5.0 mg/l), cadmium (1.0 mg/l) and mercury (0.2 mg/l).
Some examples of organic chemicals include carbon tetrachloride (0.5 mg/l), trichloroethylene (0.5 mg/l) and o-cresol, m-cresol, p-cresol (200 mg/l)
TOXIC:
Exceeds limit of TCLP test
CORROSIVE:
pH is <2 or > 12.5
D004 – D043
D002

15. What About Mixing Wastes?
Do not mix hazardous wastes with non-hazardous wastes!
 Before consolidating hazardous wastes, call the P2 Dept for guidance:
Randy Dozer –
Suzan Curtin –

16. Universal Waste EPA promulgated – May 11, 1995
Promotes collection and recycling of HW known as Universal Wastes (UW):
Lamps
Batteries
Pesticides
Mercury-containing equipment
HISTORY: EPA promulgated the Universal Waste regulations on May 11, 1995 to encourage and promote collection and recycling of certain widely generated hazardous wastes that are commonly known as universal wastes.
REGULATION: Universal Waste is regulated under 40 CFR Part 273. The ADEQ adopts this regulation through the Arizona Administrative Code R
4 TYPES of UNIVERSAL WASTE:
Lamps
Batteries
Pesticides
Mercury-containing equipment
NOTE: There are only 4 types of waste

17. Why Universal Waste?
Promotes collection and recycling of certain widely generated HW
Eases regulatory burden – allows longer accumulation time of up to 1 year
Mishandled UW can become HW
Example – broken fluorescent tubes becomes a mercury release
Your supervisor can provide you with emergency response & clean-up training about UW in your work area
Promotes collection and recycling of certain widely generated HW
Eases regulatory burden – allows longer accumulation time of up to 1 year
Mishandled universal waste can become hazardous waste
Example – broken fluorescent tubes becomes a mercury release
Your supervisor is responsible for providing you emergency response & clean-up training about UW in your work area

18. Small Quantity Handlers
UW Handler Classifications
Generators of UW are referred to as “Handlers”
Two types of Universal Waste handlers:
Large Quantity Handler (LQHUW) : Accumulates 5,000 kg (~ 11,000 lbs) or more of UW
Small Quantity Handler (SQHUW): Does not accumulates 5,000 kg or more of UW
NOTE: Accumulation is calculated collectively, at any time
All AZARNG facilities are classified as:
Small Quantity Handlers
Universal Waste Handler means:
A generator of universal waste; or
The owner or operator of a facility, including all contiguous property, that receives universal waste from other universal waste handlers, accumulates universal waste, and sends universal waste to another universal waste handler, to a destination facility, or to a foreign destination.
This definition does not include:
A person who treats (except under the provisions of 40 CFR (a) or (c), or (a) or (c)), disposes of, or recycles universal waste; or
A person engaged in the off-site transportation of universal waste by air, rail, highway, or water, including a universal waste transfer facility
Large Quantity Handler of Universal Waste—means a universal waste handler (as defined in this section) who accumulates 5,000 kilograms or more total of universal waste (batteries, pesticides, mercury-containing equipment, or lamps, calculated collectively) at any time. This designation as a large quantity handler of universal waste is retained through the end of the calendar year in which the 5,000-kilogram limit is met or exceeded.
Small Quantity Handler of Universal Waste—means a universal waste handler (as defined in this section) who does not accumulate 5,000 kilograms or more of universal waste (batteries, pesticides, mercury-containing equipment, or lamps, calculated collectively) at any time.

19. Universal Waste Labeling
Universal Waste labeling ALWAYS contains 3 items:
The words “Universal Waste”
Name of Universal Waste
Accumulation Start Date NOTE: Universal waste can only remain on-site for 1 year maximum
It is important to understand that the Universal Waste must be labeled with the words “Universal Waste”, the waste name and the start date. The start date determines the length of time waste has before being disposed.

20. Universal Waste Labeling
Batteries: “Universal Waste – “Used Battery(ies)”
Pesticides: “Universal Waste – Pesticide(s)” or “Waste – Pesticide(s)”
Lamps: “Universal Waste – Lamp(s)” or “Used Lamp(s)”

21. More Universal Waste Labeling
Mercury-containing equipment:
“Universal Waste – Mercury Containing Equipment” or “Waste Mercury – Containing Equipment” or “Used Mercury – Containing Equipment.”
Mercury-containing thermostat or container: “Universal Waste – Mercury Thermostat(s)” “Waste Mercury Thermostat(s)” or “Used Mercury Thermostat(s)”

22. Started off OK, but is now unacceptable
Started off OK, but is now unacceptable. Must withstand elements of weather while being stored.

23. Missing Accumulation Date; Avoid “Bad Bulbs” comments; Open top

24. Batteries not properly labeled; plastic container does not belong here.

25. Bulbs improperly managed

26. Material is not hazardous waste
Review HW Process
Is material a solid waste? NO
YES
Material is not hazardous waste
Is waste excluded from the definition of solid or hazardous waste?
YES NO NO
So how do we determine if we have a HW?
Is waste a listed, a characteristic or universal HW?
Waste is HAZARDOUS and subject to RCRA Subtitle C
YES
YES
Is waste delisted? NO

27. Petroleum, Oil & Lubricants
POLs:
Are not hazardous wastes – do not mix any hazardous waste into them
Require specific wording on all waste POL containers, including tanks:
USED OIL

28. Even POL Drip Containers Need Labeling!

29. EPA ID Number Provides a method to track HW
Assigned per location, can’t be shared
Defines HW generator status boundaries
Assigned to HW transporters
Must be entered on the HW manifest prior to transportation and disposal
EPA ID Numbers apply to the boundaries of a whole, contiguous facility, and not individual buildings or shops. Sometimes, such as in the case of PPMR, breaks in the property lines are allowed. PPMR is divided by McDowell Rd, but the EPA ID Number applies to both sides.

30. Our Current EPA ID Numbers
AZ Papago Park
AZ Silver Bell Army Heliport
AZ Camp Navajo
AZ Bellemont
AZ Florence
AZ Safford
AZ Valencia
Current EPA ID Numbers:
AZ Papago Park
AZ Silver Bell Army Heliport
AZ Camp Navajo
AZ Bellemont
AZ Florence
AZ Safford
AZ Valencia

31. HW Generator Status Three categories of HW generators:
Large Quantity Generator – LQG
Small Quantity Generator – SQG
Conditionally Exempt Small Quantity Generator – CESQG
PPMR, SBAH, CN are SQGs
All other AZARNG sites are CESQGs
NOTE: Category applies to whole site; individual shops or buildings are not classified separately
EPA defines a HW Generator as anyone who first creates or produces a HW; or imports a HW into the USA.

32. What Defines an LQG? Any site that generates:
Greater than 1000 kg (~2200 lbs) per calendar month of HW OR
1 kg (~2.2 lbs) or more of acutely HW per calendar month
In 2003, there were ~ 16,000 LQGs

33. LQG Requirements Emergency coordinator
90-Day accumulation time limit
Emergency coordinator
Test/maintain emergency equipment
Formal written contingency and emergency plans
Personnel participate in established training program for handling HW
LQG Highlights – more stringent
90-Day accumulation time limit
Emergency coordinator must be designated, and also a back-up
Test/maintain emergency equipment
Formal written contingency plans & emergency plans – PPMR, CN, SBAH have plans called ECM (See Dave Annis)
Personnel participate in established training program for handling HW

34. What Defines an SQG? Any facility that generates:
> 100 kg (~220 lbs) and < 1000 kg (~2200 lbs) of HW per calendar month
AND
Accumulates < 6000 kg (~13,200 lbs) of HW at any time
In 2001, there were ~200,000 SQGs

35. SQG Requirements 180-day accumulation limit Emergency coordinator:
Either on-site or on-call
Responsible for coordinating HW emergency response measures
Personnel must be familiar with procedures for:
Proper handling of HW
Emergencies relating to their specific HW and
work area
SQG Highlights – (less stringent)
180-day accumulation limit
Emergency coordinator, either on-site or on-call with basic safety info
Not required to have written contingency plans
Not required to have established training program
Ensure personnel handling HW are familiar with proper handling and emergency procedures

36. Joint LQG & SQG Requirements
LQGs / SQGs must:
Have EPA ID number
Accumulate HW, as specified by regulations
Identify, label and count HW
Comply with training and emergency preparedness requirements specified for their HW classification
Track shipment and receipt of HW and HW Manifests
Meet recordkeeping and reporting requirements
The Environmental Office is responsible for the following bullets:
Obtain an EPA ID Number (ENV)
Accumulate HW, as specified by regulations
Identify, label and count HW
Comply with training and emergency preparedness requirements specified for their HW classification
Track shipment and receipt of HW and HW Manifests
Meet recordkeeping and reporting requirements
All the other bullets are the responsibilities of the sites. The Environmental Office is always available for assistance.

37. What Defines a CESQG? Less than 100 kg (220 lbs) of HW per month
Less than 1 kg (2.2 lbs) of acutely HW per month
Limits total accumulation on-site to:
1000 kg (2200 lbs) of HW
1 kg of acute HW
100 kg of residue or contaminated soil from a clean-up of an acute HW at any time
Any facility that generates:
Less than 100 kg (220 lbs) of HW per calendar month
Or less than 1 kg (2.2 lbs) of acutely HW per calendar month
And limits total accumulation to 1000 kg (2200 lbs) of HW, 1 kg of acute HW, or 100 kg of residue or contaminated soil from a clean-up of an acute HW at any time

38. CESQG Requirements CESQGs must: Identify all HW generated on-site
Label and properly manage HW containers
Stay within accumulation limit requirements
Ensure HW is delivered to authorized TSDF (Treatment, Storage, Disposal Facility)
Inspect weekly (AZARNG)
CESQGs must:
Identify all HW generated on-site
Label and properly manage HW containers
Stay within storage limit requirements
Ensure HW is delivered to authorized TSDF (Treatment, Storage, Disposal Facility)
Inspect weekly (AZARNG) – internal policy to ensure compliance
Obtain EPA ID Number (ADEQ)

39. Episodic HW Generation
If a facility exceeds its HW generator status limits, all the HW rules for the new generator status apply immediately.
ADEQ could keep enforcing the higher level on a permanent basis.
If a facility exceeds its limits, then all the rules for the new level apply for that month
ADEQ could keep enforce the higher level on a permanent basis
Two years ago, PPMR and SBAH were downgraded to SQGs from LQGs. This has reduced regulatory burden on these facilities and we want to keep it that way!
Pay attention to your generation of Hazardous Waste!!

40. Containers
Any portable device used to store, transport, treat or handle HW
Examples: 5-gal can, 55-gal drum, tank car
Must be D.O.T. certified to transport on highways
Keep closed except for adding or removing waste
Handle so not to damage container
Containers are the most commonly used and diverse HW storage units.
Keep closed, except when adding or removing HW
Handle so as not to cause a leak
Inspect for leaks and deterioration
Meet DOT requirements when shipping
Use secondary containment when storing containers of liquid HW
EPA requires LQGs to do
AZARNG requires all facilities to do
Air emission control requirements:
EPA requires LQGs to have or install
Level 1 containers – small (26 to 119 gals) must be compliant with DOT, have closed cover or fitted with vapor suppression barrier

41. Container Inspections
Look for leaky, bulging or rusty containers
Check the labeling and marking
Check the date for compliance with time limits
Use secondary containment for liquids
Keep closed except for adding or removing HW
Inspect Satellite and Accumulation Consolidation areas on a weekly basis:
Look for leaky containers
Check the labeling and marking
Check the date – ensure compliance with storage time limits
Make sure HW accumulation uses spill containment
Keep containers lids closed
Record weekly inspections into ECMS website or by paper, if this is your assignment
Alert immediately the HW Team if you are close to exceeding your monthly HW generation limit
LIKE THIS!
NOT THIS!

42. Labels and Markings Put “Hazardous Waste” on all HW containers
Mark each container identifying the waste stream
Enter “Start Date” when container is placed in a CAA
Use indelible paint pen or paint
Enter information on side of drum, near top – never on the lid!
Labels, Marking, Placards!
Put “Hazardous Waste” on all HW containers regardless if in SAP or CAA.
Mark container identifying waste stream with indelible paint pen or paint the waste stream on the container, preferably using a stencil.
Enter “Start Date” when container is placed in accumulation consolidation area; not in satellite area until container is full. Then one has 3 days to move to AC areas
Enter information on side of drum, near top. Never put information on a lid! Lids can be switched around.
Hazardous Waste
Waste Stream Name
Start Date
XXX
YYY
ZZZ

43. What is a Satellite Accumulation Point?
Provides a place to accumulate small amounts of a HW stream in a single container until full before removing to the CAA
Beneficial to HW generators:
Saves containers
Reduces costs of HW disposals
Supports operation/process flows
Satellite Accumulation Points (SAP):
Provide a place to accumulate small amounts of a HW stream in a single container until full before removing to the CAA
Beneficial to HW generators:
Saves containers
Reduces costs of HW disposals
Supports operation/process flows

44. SAP Requirements Located at or near point of generation
Must be under the control of operator
Only 1 container per 1 HW stream, up to 55 gals max NOTE: ADEQ allows more than 1 HW stream in 1 SAP
Mark container with words
“Hazardous Waste”
Name of HW stream
Date container when it becomes full – not before
Remove full container within 3 days to the CAA
Inspect weekly – use ECMS website or paper copy
SAP Requirements:
Located at or near point of generation of HW stream
Must be under the control of operator of the process generating the HW stream
Only 1 container per one HW stream, up to 55 gals max
NOTE: ADEQ allows more than 1 HW stream in 1 SAP, but the cap per HW stream is 55 gal – means there can be 2 different HW streams accumulated in 1 SAP, each HW stream can be accumulated up to 55 gal
Mark container with words
“Hazardous Waste”
Name of HW stream
Mark container with words “Hazardous Waste” and name of HW
Date container when it becomes full, and remove container within 3 days to the CAA
Has weekly inspections

45. Satellite Accumulation Point Checklist
Example of the ECMS reporting system. This report is completed each week and can be done on line or in case of network failures can be completed on paper and stored for further reference. Reports must be kept for 3 years.
Satellite Accumulation Point Checklist

46. Central Accumulation Area (CAA)
Designated place on site for accumulating HW
Has physical requirements:
Security
Fire protection
Signage
Has accumulation time constraints:
LQG – 90 days
SQG – 180 days
Dependent on TSDF category
Central Accumulation Areas:
Accumulate HW
Have physical requirements:
Security – Restricted access to HW accumulation area and communication systems, such as telephones or 2-way radios.
Fire protection – portable fire extinguishers, water hydrants
Signage: Danger – Unauthorized Personnel Keep Out
Have storage time constraints
Keep incompatible wastes separated
Inspect weekly
Dependent on TSDF category – more stringent if permitted vs interim status

47. CAA Requirements Use appropriate container for the HW
Properly label and mark container
Record “Start Date” on container (not lid)
Keep incompatibles separate
Keep containers CLOSED, except when adding or removing waste
Use secondary containment
Accumulation Area Requirements:
NOTE: Applies to both 90-day and 180-day areas, as well as CESQG accumulation areas
Be sure container is compatible with the HW that will be placed inside it; can use a liner.
Record contents/type of HW and use appropriate labels – more on this topic later
Spill containment is required for permitted TSDFs; only one in AZARNG is the OB/OD up at Camp Navajo.
Generators of HW that have interim status do not have spill containment requirements for containers. However, best management practice would be to provide spill containment

48. CAA Requirements (continued)
Keep aisles open and free of obstructions
Record weekly inspections into ECMS website or by paper, if this is your assignment
Alert immediately the HW Team if you are close to exceeding your monthly HW generation limit – remember “Episodic Generation”?

49. CAA Emergency Requirements
Must post next to telephone:
Name and telephone number of emergency coordinator and alternate
Location of fire extinguishers and spill control material and fire alarm (if present)
Telephone number of fire department, unless facility has a direct alarm

50. Hazardous Waste Manifests
Crucial to “Cradle-to-Grave” concept
Certify HW shipments are accurately described
Allow tracking movement of HW from generator to TSDF by all parties – generator, transporter, TSDFs, EPA and State agencies
Require signatures of generator, transporter, TSDF NOTE: Only Randy, Suzan, Kevin and Hannah (Camp Navajo) are authorized to sign for AZARNG HW Manifests
MANIFEST Destiny
Manifesting HW disposals – crucial to cradle-to-grave concept
Allows all parties – generator, transporter, TSDFs, EPA and State agencies – to track movement of HW from generation to disposal
NOTE: This is critical in managing HW disposals
Manifest must be returned to generator and generator turn in the final copy to ADEQ.
LQGs – must ask TSDF after 35 days, and after 45 days do an exception report to ADEQ.
SQGs – has up to 60 days to turn in copy to ADEQ or otherwise do an exception report.
Everyone uses the Uniform HW Manifest – in effect September 5, 2006
EPA specifies information contained in manifest
Manifests certify:
Shipment accurately described
Generator has waste minimization in place
TSDF method is most practicable method to minimize risk to human health and the environment

51. What is a TSDF? TSDF – Treatment, Storage, Disposal Facility
Two categories:
Permitted – HW disposal facilities, Camp Navajo’s OB/OD
Interim Status – All other AZARNG locations
HW Generators use Interim Status requirements
Not as stringent
Can lose Interim Status, if HW generation exceeds HW status threshold (Episodic Generation)
TSDF – Treatment, storage, disposal facility
Two categories with examples:
Permitted – Disposal facilities, Camp Navajo OB/OD
Interim Status – All other AZARNG facilities
Generators of HW follow Interim Status requirements (not as stringent)
Can lose Interim Status, if HW generation exceeds category threshold – PAY ATTENTION TO HW GENERATION!!
Our HW disposal goes to TSDFs

52. HW Spills or Emergencies
If possible, stop the release & contain spill area
Mark off area
Notify your supervisor
Use appropriate items from spill clean-up kits
Properly package and label waste container
If possible, stop the release, such as plugging a leaking drum.
NOTE: Leaking drums would have to be overpacked in a proper DOT overpack container.
Rope off the area
Notify your supervisor
Use appropriate items from spill clean-up kits, such as pillows or pigs
Properly package and label waste container just like any other HW container
Call HW Dream Team for guidance and notification
IMPORTANT—If release is sizable or has unexpected reactions occurring, contact the Environmental Office for assistance
If release is sizable or has unexpected reactions occurring, contact the Environmental Office immediately for assistance:

53. Emergency Assistance 602-267-2742
If release is sizable or has unexpected reactions occurring, contact the Environmental Office immediately for assistance:

54. Know Your Hazardous Wastes
Learn what HWs are in your work area:
What are your waste streams?
Have these streams been identified for HW?
What are the hazards?
How do you respond to a HW release/emergency?
How do you handle, accumulate and dispose of HW?
Who do you contact for guidance and assistance?
Learn what HWs are in your work area:
What are your waste streams?
Identify and know your waste streams
Have these streams been identified for HW?
Characterization and Profiling new waste streams – contact Randy for assistance
What are the HW hazards?
Supervisor is responsible to provide hazard info on your HWs
How do you respond to a HW release/emergency?
Supervisor is responsible to provide release/emergency procedures info on your HWs
How do you handle, accumulate and dispose of HW?
Know your HW generator status, where the applicable SAPs are located and where the CAA is located
Who do you contact for guidance and assistance?

55. SUMMARY Use SAP and CAA points correctly
Know what kinds of HW you generate
Use SAP and CAA points correctly
Do weekly inspections, if assigned
Label, mark and date containers accurately
Do not mix wastes together
Report any deficiencies or non-compliance issues to your supervisor
Know what to do in an emergency
FINALE
Learn about the kinds of HW you generate
Use satellite accumulation points correctly
Label, mark and date containers accurately
Don’t mix wastes together unless approved by HW Dream Team
Be aware of your HW areas – report deficiencies
Do your weekly inspections, if assigned

56. Check out upcoming slides
Spot poor waste management controls
Discuss potential violations and risks
Suggest corrective actions
Test your knowledge and skills you have learned today.
What are your concerns in your work areas?

57. Used battery stored in plastic container with baking soda
Used battery stored in plastic container with baking soda. Poor housekeeping, drum stored unmarked and no secondary containment.

58. Used batteries not properly marked, dated and labeled
Used batteries not properly marked, dated and labeled. Other items are not stored with batteries.

59. Unknown liquid in open 5 gallon containers.

60. Poor management of universal waste
Poor management of universal waste. Container must be closed, labeled universal waste, used lamps, and dated. These lamps are used and must be stored in the CAA.

61. Poor housekeeping practice
Poor housekeeping practice. Boxes contain insecticides sitting outside in the environment.

62. Green tip lamps still contain mercury
Green tip lamps still contain mercury. Broken lamps now become a Hazardous Waste Product. After lamp breaks leave area for 20 minutes to allow mercury vapors to disperse. Later place debris in plastic bag and place in steel drum labeling H/W broken lamps, properly close and seal drum and date container.

63. Insecticide contents if not managed properly can present health hazards. This outdated can was disposed as a H/W

64. Drums have no labels or marking. Must be on secondary containment
Drums have no labels or marking. Must be on secondary containment. Why are these cylinders stored without being chained and in an approved storage area?

65. Full drip pan left unattended in parking lot.
Spill pans left unattended could be run over by vehicles‘ and cause damage to the environment.
Full drip pan left unattended in parking lot.

66. Environmental Health Specialist Pollution Prevention Manager
This training program was presented to you by the DEMA Environmental Office.
Our goal is to provide guidance and support to promote your HW management program.
We are available to answer questions and address concerns.
Randy Dozer –
Environmental Health Specialist
Suzan Curtin –
Pollution Prevention Manager