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RCRA: R ESOURCE C ONSERVATION & R ECOVERY A CT Arizona Army National Guard HAZARDOUS WASTE AWARENESS Training Program.

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Presentation on theme: "RCRA: R ESOURCE C ONSERVATION & R ECOVERY A CT Arizona Army National Guard HAZARDOUS WASTE AWARENESS Training Program."— Presentation transcript:

1 RCRA: R ESOURCE C ONSERVATION & R ECOVERY A CT Arizona Army National Guard HAZARDOUS WASTE AWARENESS Training Program

2 C OURSE O BJECTIVES 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

3 W HAT 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)

4 W HAT IS A RCRA S OLID W ASTE ? RCRA defines solid waste as: Garbage Refuse Sludge Industrial wastes Other discarded materials – solid, semi-solid, liquid or gaseous

5 C ONGRESSIONAL D EFINITION 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) – solid waste, which because of its quantity, concentration, or physical, chemical, or infectious characteristics may:

6 C RADLE - TO -G RAVE C ONCEPT

7 W HAT K INDS OF W ASTE D O W E H AVE ? Hazardous

8 W HY W E M ANAGE 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 W HO M ANAGES HW? Everyone who handles or works with HAZARDOUS WASTE!

10 H OW D O W E M ANAGE HW? Comprehensive HW management includes: Identification Disposal of waste Classification Documentation Accumulation Education of personnel

11 W HO TO C ONTACT FOR HW H ELP 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 I DENTIFYING H AZARDOUS W ASTE ! Listed by EPA Has at least one of these HW characteristics: Ignitable Corrosive ReactiveToxic (TCLP) Is a Universal Waste: LampsBatteries PesticidesMercury-containing Equipment Must meet at least one of these criteria:

13 EPA S L ISTED W ASTES 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

14 W HAT A RE HW C HARACTERISTICS ? IGNITABLE: <140 o F CORROSIVE: pH is 12.5 REACTIVE: Violently reacts with H2O TOXIC: Exceeds limit of TCLP test D001 D003 D002 D004 – D043

15 Do not mix hazardous wastes with non-hazardous wastes! Before consolidating hazardous wastes, call the P2 Dept for guidance: Randy Dozer – Suzan Curtin – W HAT A BOUT M IXING W ASTES ?

16 U NIVERSAL W ASTE EPA promulgated – May 11, 1995 Promotes collection and recycling of HW known as Universal Wastes (UW): Lamps Batteries Pesticides Mercury-containing equipment

17 W HY U NIVERSAL W ASTE ? 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

18 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 UW H ANDLER C LASSIFICATIONS

19 U NIVERSAL W ASTE L ABELING The words Universal Waste Name of Universal Waste Accumulation Start Date NOTE: Universal waste can only remain on-site for 1 year maximum Universal Waste labeling ALWAYS contains 3 items:

20 U NIVERSAL W ASTE L ABELING 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 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) M ORE U NIVERSAL W ASTE L ABELING

22 S TARTED OFF OK, BUT IS NOW UNACCEPTABLE. M UST WITHSTAND ELEMENTS OF WEATHER WHILE BEING STORED.

23 M ISSING A CCUMULATION D ATE ; A VOID B AD B ULBS COMMENTS ; O PEN TOP

24 B ATTERIES NOT PROPERLY LABELED ; PLASTIC CONTAINER DOES NOT BELONG HERE.

25 Bulbs improperly managed

26 R EVIEW HW P ROCESS Is material a solid waste? Is waste excluded from the definition of solid or hazardous waste? Is waste a listed, a characteristic or universal HW? Is waste delisted? Material is not hazardous waste Waste is HAZARDOUS and subject to RCRA Subtitle C NO YES NO YES NO YES NO YES

27 P ETROLEUM, O IL & L UBRICANTS Are not hazardous wastes – do not mix any hazardous waste into them Require specific wording on all waste POL containers, including tanks: USED OIL POLs:

28 E VEN POL D RIP C ONTAINERS N EED L ABELING !

29 EPA ID N UMBER Provides a method to track HW Assigned per location, cant be shared Defines HW generator status boundaries Assigned to HW transporters Must be entered on the HW manifest prior to transportation and disposal

30 O UR C URRENT EPA ID N UMBERS AZ Papago Park AZ Silver Bell Army Heliport AZ Camp Navajo AZ Bellemont AZ Florence AZ Safford AZ Valencia

31 HW G ENERATOR S TATUS 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

32 W HAT D EFINES 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

33 LQG R EQUIREMENTS 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

34 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 W HAT D EFINES AN SQG?

35 SQG R EQUIREMENTS 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

36 J OINT LQG & SQG R EQUIREMENTS 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

37 W HAT D EFINES 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

38 CESQG R EQUIREMENTS 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)

39 E PISODIC HW G ENERATION 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. Pay attention to your generation of Hazardous Waste!!

40 C ONTAINERS 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

41 C ONTAINER I NSPECTIONS 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 NOT THIS!LIKE THIS!

42 L ABELS AND M ARKINGS 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! Hazardous Waste Waste Stream Name Start Date XXX YYY ZZZ

43 W HAT IS A S ATELLITE A CCUMULATION P OINT ? 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

44 SAP R EQUIREMENTS 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

45 S ATELLITE A CCUMULATION P OINT C HECKLIST

46 C ENTRAL A CCUMULATION A REA (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

47 CAA R EQUIREMENTS 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

48 CAA R EQUIREMENTS ( 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 E MERGENCY R EQUIREMENTS 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 H AZARDOUS W ASTE M ANIFESTS 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

51 W HAT IS A TSDF? TSDF – Treatment, Storage, Disposal Facility Two categories: Permitted – HW disposal facilities, Camp Navajos 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)

52 HW S PILLS OR E MERGENCIES 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 release is sizable or has unexpected reactions occurring, contact the Environmental Office immediately for assistance:

53 E MERGENCY A SSISTANCE If release is sizable or has unexpected reactions occurring, contact the Environmental Office immediately for assistance:

54 K NOW Y OUR H AZARDOUS W ASTES 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?

55 SUMMARY 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

56 C HECK OUT UPCOMING SLIDES Spot poor waste management controls Discuss potential violations and risks Suggest corrective actions What are your concerns in your work areas?

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65 F ULL DRIP PAN LEFT UNATTENDED IN PARKING LOT.

66 T HIS TRAINING PROGRAM WAS PRESENTED TO YOU BY THE DEMA E NVIRONMENTAL O FFICE. O UR GOAL IS TO PROVIDE GUIDANCE AND SUPPORT TO PROMOTE YOUR HW MANAGEMENT PROGRAM. W E ARE AVAILABLE TO ANSWER QUESTIONS AND ADDRESS CONCERNS. R ANDY D OZER – E NVIRONMENTAL H EALTH S PECIALIST S UZAN C URTIN – P OLLUTION P REVENTION M ANAGER


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