RCRA training


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RCRA training

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RCRA training

  1. 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. 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. 3
  4. 4. Material or Waste? • What is the difference between materials and wastes? 4
  5. 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. 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. 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. 8
  9. 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
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  13. 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. 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. 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. 16
  17. 17. Hazardous Waste Management 17
  19. 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. 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
  22. 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. 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. 24. Hazardous Wastes  Are SolidWastes  May be CHARACTERISTIC or LISTED Hazardous Wastes  Include UniversalWastes, but they are managed differently 24
  25. 25. Hazardous Wastes: Four types of Characteristic Wastes  IGNITABLE  CORROSIVE  REACTIVE  TOXIC 25
  26. 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. 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. 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. 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. 30. Let’s Review True or False?  “Solid Waste” as defined under RCRA may be a solid, liquid, or gas It’sTrue 30
  31. 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. 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. 33. HW Generator Requirements 33
  34. 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. 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. 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. 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. 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. 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. 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. 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. 42. HW Generation Points 43
  43. 43. HW Generation Point Sign 44
  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. 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. 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. 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. 48. Wastes and How to Manage Them Think about the wastes you generate at your facility 49
  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. 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. 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. 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. 53. Management of Other Wastes 54
  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. 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. 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. 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. 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. 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. 60. Universal Wastes 61
  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. 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. 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. 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. 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. 66. Waste Identification Exercise 67
  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. 68. Que pasa? ? 69
  69. 69. Que pasa? ? 70
  70. 70. Que pasa? ? 71
  71. 71. Que pasa? ? 72
  72. 72. Que pasa? ? 73
  73. 73. Que pasa? ? 74
  74. 74. Que pasa? ? 75
  75. 75. Que pasa? ? 76
  76. 76. Spills • What you need to know –Prevent –Prepare –Respond –Report 77
  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. 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. 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. 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. 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. 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. 83. Spill Reporting 84
  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. 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