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RCRA training

RCRA training

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  • 1. Resource Conservation and Recovery Act (RCRA) Waste Site Management USAG Fort Buchanan Puerto Rico Conducted by US Army Public Health Command APG, MD 1
  • 2. Overview • Managing Hazardous Materials • Resource Conservation and Recovery Act (RCRA) • Types of wastes (Hazardous, Solid, Universal) • Managing your operational and waste sites • Preventing and Responding to Spills 2
  • 3. 3
  • 4. Material or Waste? • What is the difference between materials and wastes? 4
  • 5. What are Hazardous Materials? Materials that may:  Cause an increase in mortality or illness  Pose a substantial hazard to human health or the environment when mismanaged 5
  • 6. Hazardous Material Storage  Hazardous materials are the items in supply (i.e., virgin products, items still being used).  Typical storage areas include flammable cabinets, paint lockers, etc 6
  • 7. Your HazMat Storage Area Checklist  Verify that appropriate signs are posted, to include emergency POC list  Check for leaking and damaged containers  Check for proper segregation  Verify there is secondary containment  Ensure all containers are properly labeled and that the labels are in good shape  Check for MSDSs/SDS and inventory  Verify that those working with HazMat have received HAZCOM training  Check for correct stock rotation and ordering practices (good management practice) 7
  • 8. 8
  • 9. Safety Data Sheets  The Globally Harmonized System of Classification and Labeling of Chemicals (GHS) is an international system of chemical classification, labeling, and hazard communication adopted by the United Nations.  The goal is to improve worker safety and health by providing easy to understand chemical hazard information on labels and in Safety Data Sheets.  Section 7 - handling and storage, including incompatibilities 9
  • 10. 10
  • 11. 11
  • 12. 12
  • 13. If an SDS is not available, obtain it from the Hazardous Materials Information Resource System (HMIRS) by accessing http://www.dlis.dla.mil/hmirs/. Another source of MSDSs on the internet is http://www.ilpi.com/msds/ 13
  • 14. GHS Phase In  By December 1, 2013, all Soldiers,Army civilians, and embedded contractors must be trained on the new label elements and SDS format.  By June 1, 2016, all Army organizations will be required to have integrated GHS into their existing Hazard Communication program and must have:  Completed transition to new workplace labeling,  Made sure SDSs are available on every chemical and have replaced all existing MSDS sheets, and  Have provided additional employee training for newly identified physical or health hazards. 14
  • 15. HM Segregation Guidelines  Flammable and combustible liquids should be stored in labeled flammable storage cabinets.  Keep containers closed when not using.  Acids should be kept separate from bases (caustics), flammables should not be stored with corrosives or oxidizers.  Turn in excess materials if they have expired, are unusable, or have no current or anticipated application. 15
  • 16. 16
  • 17. Hazardous Waste Management 17
  • 18. RESOURCE CONSERVATION AND RECOVERY ACT (RCRA)  ENACTED IN 1976  IMPLEMENTING REGULATIONS IN 1980  HAZARDOUS AND SOLIDWASTE AMENDMENTS OF 1984  FEDERAL FACILITIES COMPLIANCE ACT OF 1992 18
  • 19. GOAL OF RCRA  “Cradle to Grave” management of waste  Management of waste from point of generation to point of disposal  Waste generator is ultimately responsible Generation Transportation Disposal 19
  • 20. ENVIRONMENTAL LIABILITY  Civil actions  $32,500/day/violation  No Criminal Penalty Assigned  Criminal actions  $37,500/day/violation  Up to 5 years imprisonment  3 Types  Negligent Actions  Knowing Actions  Knowing Endangerment 20
  • 21. RCRA REGULATIONS 40 CFR 260-271  IDENTIFICATION AND LISTING OF HAZARDOUS WASTE - PART 261  GENERATOR REQUIREMENTS - PART 262  TRANSPORTER REQUIREMENTS - PART 263  TREATMENT, STORAGE and DISPOSAL REQUIREMENTS - PART 264 & 265 21
  • 22. PUERTO RICO REGULATIONS  Puerto Rico follows the RCRA HW regulations  Environmental Public Policy Act of 1970  Puerto Rico Environmental Quality Board (PREQB) Regulation 5717, Regulation for the Control of Dangerous Solid Waste  regulates the management and operations of non-hazardous waste disposal facilities, to include biomedical waste, used oil, tires and compost.  PR Regulation 2863 (ChapterVII, Rules 604 and 642) requires generators of used oil to register with the PREQB and obtain a Used Oil Generator ID number Remember: Used Oil containers greater than 220 gallons require special permit 22
  • 23. SOLID WASTE DEFINITION  Any discarded material not excluded by 40 CFR 261.4:  Domestic sewage, industrial wastewater, scrap metal or circuit boards being recycled  DISCARDED means:  Abandoned  Recycled  Inherently waste-like  Military munitions  Can be solid, liquid, gas 23
  • 24. Hazardous Wastes  Are SolidWastes  May be CHARACTERISTIC or LISTED Hazardous Wastes  Include UniversalWastes, but they are managed differently 24
  • 25. Hazardous Wastes: Four types of Characteristic Wastes  IGNITABLE  CORROSIVE  REACTIVE  TOXIC 25
  • 26. IGNITABLE WASTES  Can create fires under certain conditions, are spontaneously combustible, or have a Flash Point <140 degrees F  Includes Ignitable Compressed Gas  EPAWaste Number D001  Examples: used solvents 26
  • 27. CORROSIVE WASTES  Aqueous solutions with a pH of less than or equal to 2 OR greater than or equal to12.5  Liquids that corrodes steel at a rate of .25 inches per year  Includes acids and bases  EPAWaste Number DOO2  Examples: battery acids, lime 27
  • 28. REACTIVE WASTES  Unstable under “normal” conditions, causing explosions, toxic fumes, gases, or vapors when heated, compressed, or mixed with water  EPAWaste Number DOO3  Examples are lithium-sulfur batteries and explosives 28
  • 29. TOXIC WASTES  May be harmful or fatal when ingested or absorbed  Defined through the Toxicity Characteristic Leaching Procedure (TCLP)  40 CFR 261.24 lists specified TCLP limits for 40 contaminants (such as lead and mercury)  EPAWaste Numbers D004-D043  Examples are metal-contaminated parts cleaning solutions, lead in paint scrapings 29
  • 30. Let’s Review True or False?  “Solid Waste” as defined under RCRA may be a solid, liquid, or gas It’sTrue 30
  • 31. Let’s Review  There are four types of RCRA “Characteristic” wastes. Which of these is NOT a type of characteristic waste?  Reactive  Toxic  Dangerous  Corrosive 31
  • 32. Listed Hazardous Wastes  F-Listed:Wastes from the processes of non-specific sources. These wastes would be the most common type of "listed" waste generated by Fort Buchanan.  Examples: solvents, paint thinners, weapons cleaners  K-Listed:Wastes from specific sources from manufacturing operations.These wastes are defined by the industry in which they are generated.  Examples: petroleum refining, wood preservation, pesticides  P-Listed: Discarded unused chemicals in pure form, commercial grade, or as sole active ingredient; acutely hazardous.  U-Listed: Discarded unused chemicals in pure form, commercial grade, or as sole active ingredient. 32
  • 33. HW Generator Requirements 33
  • 34. CATEGORIES OF HW GENERATORS CONDITIONALLY EXEMPT < 100 KG/MO SMALL QUANTITY (SQG) 100 -1000 KG/MO LARGE QUANTITY > 1000 KG/MO (One 55-gallon drum = about 200 KG) 34
  • 35. Quantity Limits for SQGs  Generate: Up to 1,000 kg (2200 lbs) may be generated in a calendar month (about 5 drums)  Store: Total onsite accumulation may not exceed 6000 kg (13,200 lbs) at any time (about 30 drums) Remember: all of USAG Fort Buchanan is considered to be a single generator 35
  • 36. Generator Requirements  According to RCRA, all generators must characterize their waste streams, through  Generator’s knowledge or MSDS  Laboratory Analysis  Identification as ListedWaste  At USAG Fort Buchanan  Contact Environmental Office for assistance in characterizing waste streams  Fill out DRMS Form 1930, Hazardous Waste Profile Sheet and provide to Environmental Office 37
  • 37. CONTAINER MANAGEMENT  Good condition  Compatible with the contents of the container  Container kept closed when no one is adding or removing waste Remember: Corrosive wastes should be stored in plastic, or plastic-lined steel drums. 38
  • 38. CONTAINER MANAGEMENT  Labels must be visible on containers  Must not be stored or handled in a way causing it to leak  Should not be overfilled  Should not be stored exposed to rain 39
  • 39. EMPTY CONTAINERS  A container that held HW is empty if as much waste as possible was removed using common methods (pouring, pumping, aspirating)  Labels/markings that no longer apply must be removed or painted over Remember: Containers that held an acute HW must be triple rinsed before reusing. 40
  • 40. HW GENERATION POINTS  HW may be stored where it is being generated, at the HW generation point (also called “satellite accumulation point”), for an unlimited time  The waste must be:  At or near the point of generation  Under the direct control of the person(s) generating it  In containers marked with words “HAZARDOUS WASTE” or identifying the contents  In containers with completed HW labels that are visible  Segregated if more than one waste stream  Removed within 3 days (72 hours) after reaching 55 gallons  Labeled with accumulation start date after reaching 55 gallons 41
  • 41. HW GENERATION POINTS  HW may be stored for unlimited time where it is being generated, at the HW generation point  According to Ft Buchanan’s Hazardous Waste Management Plan, the site must:  Have secondary containment if liquids are stored  Have a sign with contact information  Be managed by people who are trained  Have spill control equipment available  Receive weekly inspections  Not exceed 55 gallons total HW at the generation point Plan Ahead: when container is nearly full, contact the env office for pickup 42
  • 42. HW Generation Points 43
  • 43. HW Generation Point Sign 44
  • 44. Let’s Review  HazardousWaste Generation Points must have all the following except ???  Labeled containers  A sign with emergency contact information  Spill control equipment available  A designated smoking area  A limit of 55 gallons total HW  Trained personnel in control of the site 45
  • 45. Let’s Review Which statement best describes the overall intent of the Resource Conservation and Recovery Act (RCRA) regarding responsibilities?  Wastes must be primarily managed by those operating the disposal sites such as landfills and incinerators  Wastes must be managed “cradle to grave,” with much of the responsibility on the waste generator  The Environmental Protection Agency is responsible for waste management 46
  • 46. HW 180-Day Storage Areas  When a waste accumulates 55 gallons, it must be removed from the HW Generation Area within 72 hours  It may be taken to a HW Storage area OR removed from the installation by a contractor  That day’s date must be placed on the container 72 HoursFULL HW Generation Point HW 180-Day Storage Area 47
  • 47. 180-DAY STORAGE AREAS  No limit on quantity stored  Storage time limited to 180 days  Secondary containment  Labeled “HAZARDOUS WASTE”  Accumulation start date  Communication system  Fire and spill control equipment  Emergency procedures  Weekly inspections  Locked when not in use  Training Locations of all HW storage areas must be approved by the Env Office Storage time can be increased to 270 days when HW is shipped over 200 miles 48
  • 48. Wastes and How to Manage Them Think about the wastes you generate at your facility 49
  • 49. Batteries  Batteries contain heavy metals such as mercury, lead, cadmium, and nickel, which can contaminate the environment when improperly disposed of. 50
  • 50. Lead Acid Batteries  Exempt from HW regulations when reclaimed through an approved recycling program.  Lead acid batteries that are leaking or damaged must be managed as HW and placed in appropriate containers. Contact the Environmental Office for over-pack drums.  New and used batteries must be stored in areas protected from the weather. 51
  • 51. Non-Lead Acid Batteries  Lithium, lithium-ion, nickel metal hydride, Ni-Cad, magnesium and mercury batteries MAY be managed as UW.  As a Best Management Practice, all batteries are to be collected and stored in approved plastic containers with closeable tops.  Containers must be labeled as “Used Batteries” Waste determinations made by Environmental Office. 52
  • 52. Paint and Paint-Related Material  Paint and paint-related material could contain chemicals that make them hazardous.  Most paints fall into one of two categories: water- based or oil-based.  Water-based paints: latex, vinyl or acrylic.  Oil-based paints: varnish or polyurethane.  Water-based paints are generally not regulated and if empty may be placed in the trash.  Oil-based paints are regulated due to their flammability and presence of VOCs and must be turned in. Contact Environmental Office for proper turn-in procedures. 53
  • 53. Management of Other Wastes 54
  • 54. Non-Hazardous Wastes That Require Special Handling  Some wastes generated by USAG FT Buchanan are not considered HWs but still require special handling in accordance with the HW Management Plan. These include:  Used oil  Oil filters  Fuel filters  Antifreeze  Used dry sweep/absorbents  Aerosol cans 55
  • 55. Used Oil  Used oil is considered a recyclable material (it is only a HW if it’s been contaminated with a listed HW)  Storage requirements include:  Maintain an adequate number of containers on hand  Leave a 3-inch headspace in the container for expansion  Keep containers in good condition (not leaking, rusted, etc)  Ensure containers have a cover or lid that seals tightly  If funnels are used, they must be the kind that prevent spills if tipped over  Containers should be marked “used oil” with a non- hazardous waste label Generators of used oil must register and obtain a Used Oil Generator ID number from the PR Environmental Quality Board 56
  • 56. Oil Filters  Oil filters (and diesel filters) should be drained to capture residual oil before disposal  Drained filters should then be placed in 55-gallon drums with tight-fitting lids  Containers should be marked “Used Fuel Filters” or “Used Oil Filters” 57
  • 57. Used Antifreeze  Used antifreeze is not a HW unless it has been mixed with other wastes such as solvents or fuels. It should be recycled and managed as a non-hazardous waste.  Apply a non-hazardous waste label to the container and mark it with the words “used antifreeze.” 58
  • 58. Dry Sweep/Absorbents  Absorbents contaminated with HW (solvents, paint thinner) must be managed as HW. Collect in 55-gallon drum with a HW label and the words “solvent-contaminated absorbents.” Container must be closed when not adding wastes.  Absorbents contaminated with POL are non- hazardous wastes. Collect in 55-gallon drum with non-HW label and the words “used absorbents.” 59
  • 59. Aerosol Cans  Aerosol cans are considered recyclable scrap metal when empty and punctured.  The Environmental Division and some maintenance sites have puncturing devices for venting and emptying cans.  For locations where there is no puncturing device, empty cans should be collected in a drum with a non-HW label and the words “Empty Aerosol Cans.”  Residue (contents) from puncturing devices should be collected and managed as HW. 60
  • 60. Universal Wastes 61
  • 61. Universal Wastes  UniversalWaste (UW) regulations were passed to allow REDUCED regulatory requirements on some commonly generated hazardous wastes  Batteries  Lamps containing mercury  Mercury switches  Recalled pesticides  UniversalWaste “Generators” are called handlers  Small Quantity Handlers may accumulate < 5000 Kgs total of all UW at any time  Large Quantity Handlers may accumulate > 5000 Kgs total of all UW at any time 62
  • 62. UW Management Requirements for Small & Large Quantity Handlers  Marking/labeling  Each UW or the container in which the UWs are stored must be marked/labeled:  UW-batteries: waste batteries, used batteries  UW- lamps: waste lamps, used lamps 63
  • 63. UW Management Requirements for Small & Large Quantity Handlers  Storage  Items must be in containers that are structurally sound and adequate to prevent breakage  Containers must be closed 64
  • 64. UW Management Requirements for Small & Large Quantity Handlers  AccumulationTimes  Cannot be stored for longer than ONEYEAR  Must be able to demonstrate the length of time the UW has been stored  Place start date on UW  Maintain a log 65
  • 65. UW Tracking Requirements  Small Quantity Handlers  No requirement for keeping records of off-site UW shipments  Large Quantity Handlers  Must keep records of all off-site shipments  Name and address of UW handler  Name and address of destination facility  Quantity and type of UW  Date of shipment  Records must be maintained for 3 years USAG Fort Buchanan is considered a Large Quantity UW Handler 66
  • 66. Waste Identification Exercise 67
  • 67. Identifying Storage Issues  Look at the following photos to determine what is wrong with the scenario.  What requirement for containers or storage areas is not being followed? 68
  • 68. Que pasa? ? 69
  • 69. Que pasa? ? 70
  • 70. Que pasa? ? 71
  • 71. Que pasa? ? 72
  • 72. Que pasa? ? 73
  • 73. Que pasa? ? 74
  • 74. Que pasa? ? 75
  • 75. Que pasa? ? 76
  • 76. Spills • What you need to know –Prevent –Prepare –Respond –Report 77
  • 77. Spill Terminology  Regulated “oil” includes  Petroleum-based oils  Fuel oil, motor oil, gasoline, distillates, hydraulic fluids  Oil mixed with wastes  Animal and vegetable oils  “Container” includes  Bulk storage containers (55 gallons or greater) and operational equipment 78
  • 78. Prevent  Conduct inspections of waste and material areas as required  Take action when discovering containers in poor condition  Remove obstacles from container areas to prevent trips and falls  Take precautions when transferring any materials (ask for assistance, use PPE, do not overfill) 79
  • 79. Prepare  Be familiar with spill plan and procedures  Know what’s in the containers in your work area  Use MSDSs and labels  Make sure spill kits are available  Provide secondary containment  Substitute hazardous materials with environmentally friendly products 80
  • 80. How Do Spills Happen?  Container failure (ruptures, leaks)  Transfer of materials (pouring, siphoning)  Tank overfill  Piping failure (ruptures, leaks)  Explosion or fire 81
  • 81. Respond  If POL spill less than 5 gallons on an impervious surface:  Clean up spill using spill kits and absorbents  If POL spill that contacts ground or surface water OR Hazardous Material spill of any size:  Dial 911 [(787) 707-5911, x5911 from installation phones]  Stop the flow  Protect life, property, and the environment  Notify Environmental Office (787) 707-3575, (787) 354-1861  Await emergency response personnel 82
  • 82. Report  The Fort Buchanan DPW Environmental office is responsible for reporting applicable spills  Reporting may include the National Response Center, Puerto Rico EQB, Puerto Rico Emergency Response Commission, and IMCOM-SE  YOU can help by providing the appropriate information  How the spill occurred  What material/waste was spilled  The amount of the spill  Any cleanup procedures that were taken 83
  • 83. Spill Reporting 84
  • 84. Let’s Review  All of the following (except one) are ways to prevent spills or prepare for them. Which one is not?  Make sure spill kits are available  Identify the contents of the containers stored  Stack containers on top of each other to save space  Remove obstacles from the storage area to prevent trips and falls  Conduct inspections of containers and take action when a poor container is discovered  Provide secondary containment 85
  • 85. Let’s Review  What would be the appropriate actions to take for a spill of 20 gallons of POL onto the ground?  Call 911 (787-707-5911)  Stop the flow  Protect life, property, and the environment  Notify environmental office (787-707-3575)  Await emergency response personnel 86
  • 86. YOU ARE READY FOR THE TEST! 87