1 RCRA: Resource Conservation & Recovery Act Arizona Army National GuardHAZARDOUS WASTE AWARENESSTraining ProgramWhat 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 RCRADefinitions – solid and hazardous wastesIdentification of hazardous wastes (HW)Management of HWClassification of HW generatorsAccumulation and inspections of HWManagement of containersDisposal of HWEmergenciesBest 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 Act40 CFR Parts 260 – 273 regulates hazardous waste (HW)State of Arizona and NGB enacted their own:Arizona Administrative Code Title 18, Chapter 8AR 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 ADEQgive this program reference and monitor work activities.
4 What is a RCRA Solid Waste? RCRA defines solid waste as:GarbageRefuseSludgeIndustrial wastesOther discarded materials – solid, semi-solid, liquid or gaseousRCRA defines solid waste as:Garbage – milk cartons, coffee groundsRefuse – metal scrap, wall board, empty containersSludges – from water supply treatment plants, waste treatment plants, pollution control equipmentIndustrial wastes – Manufacturing process wastewaters and non-wastewater sludges and solidsOther discarded materials – solid, semi-solid, liquid, or gaseousRCRA defines discarded solid wastes as:AbandonedRecycledInherently 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 illnessPose a present or potential hazard to the environment or human health or when improperly managedHazardous 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, illnessPose 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? HazardousRecyclablesUsed OilGive examples of each kind of waste.Medical WasteRegulated WasteSolid Waste
8 Why We Manage HW AZARNG committed to environmental compliance Federal and State laws require proper HW managementImproper HW waste management can:Adversely affect public health and the environmentCause financial and criminal penalties to offenders
9 who handles or works with Who Manages HW?Everyonewho handles or works withHAZARDOUS WASTE!
10 How Do We Manage HW? Comprehensive HW management includes: IdentificationDisposal of wasteClassificationDocumentationAccumulationEducation of personnelIdentify 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 OfficeSuzan Curtin – P2 Mgr –Randy Dozer – Env Health Spec –Kevin King – Haz Matl Spec –Environmental OfficeMAJ John Ladd – Env Program Mgr –Mary Westdyke – Env Administrative Asst –
12 Identifying Hazardous Waste! Must meet at least one of these criteria:Listed by EPAHas at least one of these HW characteristics: Ignitable Corrosive Reactive Toxic (TCLP)Is a Universal Waste: Lamps BatteriesPesticides Mercury-containing EquipmentBefore 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 EPAHas 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 processesCertain sectors of industryUnused pure chemical products and formulationsList definitions:P – acutely toxic, fatal to humansU – toxic chemicals that display other characteristicsF – nonspecific sourcesK – specific sourcesListed wastes come from:Generic industrial processesCertain sectors of industryUnused pure chemicalThese waste codes on entered on the waste manifest sheet to properly identify each waste source:P – acutely toxic, fatal to humansU – toxic chemicals that display other characteristicsF – nonspecific sourcesK – specific sourcesEPA 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 environmentAcute Hazardous – dangerous chemicals that can pose a threat to human health & the environment; fatal to humans & animals in low dosesCharacteristic – 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, UF List: Wastes from nonspecific sourcesK List: Wastes from specific sourcesPure or commercial formulations of specific unused chemicals apply to:P List: Acutely toxic; fatal to humansU List: Toxic chemicals that display other characteristics, such as ignitable or reactiveF 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 useElectroplating 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 ListsK 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 listThe chemical in the waste must be unusedThe chemical in the waste must be a commercial chemical product (CCP)Definitions of a CCP include:100% PureTechnical gradeSole active ingredientNOTE: 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 H2OIGNITABLE:<140oFD001D003HW 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 <140FMost 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 fumesThere are no accurate tests, so EPA uses a narrative to make a determination:Explodes or reacts violently when exposed to water under normal conditionsCreates toxic fumes or gases at a hazardous level when exposed to water under normal conditionsExplodes if heated under confinement, or exposed to a strong igniting source, or meets the DOT classification as an explosiveGenerates toxic levels of sulfide or cyanide gas when exposed to a pH range of 2.5 – 12.5TOXICITY – this category is for those chemicals that would be harmful in leachate because of threats to the drinking water suppliesThe 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 testCORROSIVE:pH is <2 or > 12.5D004 – D043D002
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):LampsBatteriesPesticidesMercury-containing equipmentHISTORY: 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 R4 TYPES of UNIVERSAL WASTE:LampsBatteriesPesticidesMercury-containing equipmentNOTE: There are only 4 types of waste
17 Why Universal Waste?Promotes collection and recycling of certain widely generated HWEases regulatory burden – allows longer accumulation time of up to 1 yearMishandled UW can become HWExample – broken fluorescent tubes becomes a mercury releaseYour supervisor can provide you with emergency response & clean-up training about UW in your work areaPromotes collection and recycling of certain widely generated HWEases regulatory burden – allows longer accumulation time of up to 1 yearMishandled universal waste can become hazardous wasteExample – broken fluorescent tubes becomes a mercury releaseYour supervisor is responsible for providing you emergency response & clean-up training about UW in your work area
18 Small Quantity Handlers UW Handler ClassificationsGenerators 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 UWSmall Quantity Handler (SQHUW): Does not accumulates 5,000 kg or more of UWNOTE: Accumulation is calculated collectively, at any timeAll AZARNG facilities are classified as:Small Quantity HandlersUniversal Waste Handler means:A generator of universal waste; orThe 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; orA person engaged in the off-site transportation of universal waste by air, rail, highway, or water, including a universal waste transfer facilityLarge 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 WasteAccumulation Start Date NOTE: Universal waste can only remain on-site for 1 year maximumIt 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.
26 Material is not hazardous waste Review HW ProcessIs material a solid waste?NOYESMaterial is not hazardous wasteIs waste excluded from the definition of solid or hazardous waste?YESNONOSo 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 CYESYESIs waste delisted?NO
27 Petroleum, Oil & Lubricants POLs:Are not hazardous wastes – do not mix any hazardous waste into themRequire specific wording on all waste POL containers, including tanks:USED OIL
29 EPA ID Number Provides a method to track HW Assigned per location, can’t be sharedDefines HW generator status boundariesAssigned to HW transportersMust be entered on the HW manifest prior to transportation and disposalEPA 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 ParkAZ Silver Bell Army HeliportAZ Camp NavajoAZ BellemontAZ FlorenceAZ SaffordAZ ValenciaCurrent EPA ID Numbers:AZ Papago ParkAZ Silver Bell Army HeliportAZ Camp NavajoAZ BellemontAZ FlorenceAZ SaffordAZ Valencia
31 HW Generator Status Three categories of HW generators: Large Quantity Generator – LQGSmall Quantity Generator – SQGConditionally Exempt Small Quantity Generator – CESQGPPMR, SBAH, CN are SQGsAll other AZARNG sites are CESQGsNOTE: Category applies to whole site; individual shops or buildings are not classified separatelyEPA 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 HWOR1 kg (~2.2 lbs) or more of acutely HW per calendar monthIn 2003, there were ~ 16,000 LQGs
33 LQG Requirements Emergency coordinator 90-Day accumulation time limitEmergency coordinatorTest/maintain emergency equipmentFormal written contingency and emergency plansPersonnel participate in established training program for handling HWLQG Highlights – more stringent90-Day accumulation time limitEmergency coordinator must be designated, and also a back-upTest/maintain emergency equipmentFormal 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 monthANDAccumulates < 6000 kg (~13,200 lbs) of HW at any timeIn 2001, there were ~200,000 SQGs
35 SQG Requirements 180-day accumulation limit Emergency coordinator: Either on-site or on-callResponsible for coordinating HW emergency response measuresPersonnel must be familiar with procedures for:Proper handling of HWEmergencies relating to their specific HW andwork areaSQG Highlights – (less stringent)180-day accumulation limitEmergency coordinator, either on-site or on-call with basic safety infoNot required to have written contingency plansNot required to have established training programEnsure personnel handling HW are familiar with proper handling and emergency procedures
36 Joint LQG & SQG Requirements LQGs / SQGs must:Have EPA ID numberAccumulate HW, as specified by regulationsIdentify, label and count HWComply with training and emergency preparedness requirements specified for their HW classificationTrack shipment and receipt of HW and HW ManifestsMeet recordkeeping and reporting requirementsThe Environmental Office is responsible for the following bullets:Obtain an EPA ID Number (ENV)Accumulate HW, as specified by regulationsIdentify, label and count HWComply with training and emergency preparedness requirements specified for their HW classificationTrack shipment and receipt of HW and HW ManifestsMeet recordkeeping and reporting requirementsAll 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 monthLimits total accumulation on-site to:1000 kg (2200 lbs) of HW1 kg of acute HW100 kg of residue or contaminated soil from a clean-up of an acute HW at any timeAny facility that generates:Less than 100 kg (220 lbs) of HW per calendar monthOr less than 1 kg (2.2 lbs) of acutely HW per calendar monthAnd 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 containersStay within accumulation limit requirementsEnsure HW is delivered to authorized TSDF (Treatment, Storage, Disposal Facility)Inspect weekly (AZARNG)CESQGs must:Identify all HW generated on-siteLabel and properly manage HW containersStay within storage limit requirementsEnsure HW is delivered to authorized TSDF (Treatment, Storage, Disposal Facility)Inspect weekly (AZARNG) – internal policy to ensure complianceObtain 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 monthADEQ could keep enforce the higher level on a permanent basisTwo 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 ContainersAny portable device used to store, transport, treat or handle HWExamples: 5-gal can, 55-gal drum, tank carMust be D.O.T. certified to transport on highwaysKeep closed except for adding or removing wasteHandle so not to damage containerContainers are the most commonly used and diverse HW storage units.Keep closed, except when adding or removing HWHandle so as not to cause a leakInspect for leaks and deteriorationMeet DOT requirements when shippingUse secondary containment when storing containers of liquid HWEPA requires LQGs to doAZARNG requires all facilities to doAir emission control requirements:EPA requires LQGs to have or installLevel 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 containersCheck the labeling and markingCheck the date for compliance with time limitsUse secondary containment for liquidsKeep closed except for adding or removing HWInspect Satellite and Accumulation Consolidation areas on a weekly basis:Look for leaky containersCheck the labeling and markingCheck the date – ensure compliance with storage time limitsMake sure HW accumulation uses spill containmentKeep containers lids closedRecord weekly inspections into ECMS website or by paper, if this is your assignmentAlert immediately the HW Team if you are close to exceeding your monthly HW generation limitLIKE THIS!NOT THIS!
42 Labels and Markings Put “Hazardous Waste” on all HW containers Mark each container identifying the waste streamEnter “Start Date” when container is placed in a CAAUse indelible paint pen or paintEnter 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 areasEnter information on side of drum, near top. Never put information on a lid! Lids can be switched around.Hazardous WasteWaste Stream NameStart DateXXXYYYZZZ
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 CAABeneficial to HW generators:Saves containersReduces costs of HW disposalsSupports operation/process flowsSatellite Accumulation Points (SAP):Provide a place to accumulate small amounts of a HW stream in a single container until full before removing to the CAABeneficial to HW generators:Saves containersReduces costs of HW disposalsSupports operation/process flows
44 SAP Requirements Located at or near point of generation Must be under the control of operatorOnly 1 container per 1 HW stream, up to 55 gals max NOTE: ADEQ allows more than 1 HW stream in 1 SAPMark container with words“Hazardous Waste”Name of HW streamDate container when it becomes full – not beforeRemove full container within 3 days to the CAAInspect weekly – use ECMS website or paper copySAP Requirements:Located at or near point of generation of HW streamMust be under the control of operator of the process generating the HW streamOnly 1 container per one HW stream, up to 55 gals maxNOTE: 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 galMark container with words“Hazardous Waste”Name of HW streamMark container with words “Hazardous Waste” and name of HWDate container when it becomes full, and remove container within 3 days to the CAAHas 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 HWHas physical requirements:SecurityFire protectionSignageHas accumulation time constraints:LQG – 90 daysSQG – 180 daysDependent on TSDF categoryCentral Accumulation Areas:Accumulate HWHave 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 hydrantsSignage: Danger – Unauthorized Personnel Keep OutHave storage time constraintsKeep incompatible wastes separatedInspect weeklyDependent on TSDF category – more stringent if permitted vs interim status
47 CAA Requirements Use appropriate container for the HW Properly label and mark containerRecord “Start Date” on container (not lid)Keep incompatibles separateKeep containers CLOSED, except when adding or removing wasteUse secondary containmentAccumulation Area Requirements:NOTE: Applies to both 90-day and 180-day areas, as well as CESQG accumulation areasBe 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 laterSpill 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 obstructionsRecord weekly inspections into ECMS website or by paper, if this is your assignmentAlert 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 alternateLocation 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” conceptCertify HW shipments are accurately describedAllow tracking movement of HW from generator to TSDF by all parties – generator, transporter, TSDFs, EPA and State agenciesRequire signatures of generator, transporter, TSDF NOTE: Only Randy, Suzan, Kevin and Hannah (Camp Navajo) are authorized to sign for AZARNG HW ManifestsMANIFEST DestinyManifesting HW disposals – crucial to cradle-to-grave conceptAllows all parties – generator, transporter, TSDFs, EPA and State agencies – to track movement of HW from generation to disposalNOTE: This is critical in managing HW disposalsManifest 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, 2006EPA specifies information contained in manifestManifests certify:Shipment accurately describedGenerator has waste minimization in placeTSDF 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/ODInterim Status – All other AZARNG locationsHW Generators use Interim Status requirementsNot as stringentCan lose Interim Status, if HW generation exceeds HW status threshold (Episodic Generation)TSDF – Treatment, storage, disposal facilityTwo categories with examples:Permitted – Disposal facilities, Camp Navajo OB/ODInterim Status – All other AZARNG facilitiesGenerators 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 areaMark off areaNotify your supervisorUse appropriate items from spill clean-up kitsProperly package and label waste containerIf 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 areaNotify your supervisorUse appropriate items from spill clean-up kits, such as pillows or pigsProperly package and label waste container just like any other HW containerCall HW Dream Team for guidance and notificationIMPORTANT—If release is sizable or has unexpected reactions occurring, contact the Environmental Office for assistanceIf 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 streamsHave these streams been identified for HW?Characterization and Profiling new waste streams – contact Randy for assistanceWhat are the HW hazards?Supervisor is responsible to provide hazard info on your HWsHow do you respond to a HW release/emergency?Supervisor is responsible to provide release/emergency procedures info on your HWsHow do you handle, accumulate and dispose of HW?Know your HW generator status, where the applicable SAPs are located and where the CAA is locatedWho do you contact for guidance and assistance?
55 SUMMARY Use SAP and CAA points correctly Know what kinds of HW you generateUse SAP and CAA points correctlyDo weekly inspections, if assignedLabel, mark and date containers accuratelyDo not mix wastes togetherReport any deficiencies or non-compliance issues to your supervisorKnow what to do in an emergencyFINALELearn about the kinds of HW you generateUse satellite accumulation points correctlyLabel, mark and date containers accuratelyDon’t mix wastes together unless approved by HW Dream TeamBe aware of your HW areas – report deficienciesDo your weekly inspections, if assigned
56 Check out upcoming slides Spot poor waste management controlsDiscuss potential violations and risksSuggest corrective actionsTest 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.
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 SpecialistSuzan Curtin –Pollution Prevention Manager
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