rcra training basics - waste site mangement, us army puerto rico
TRANSCRIPT
Resource Conservation and Recovery Act (RCRA)Waste Site Management
USAG Fort BuchananPuerto Rico
Conducted byUS Army Public Health CommandAPG, MD
1
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
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
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
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
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
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
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
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
RESOURCE CONSERVATION AND
RECOVERY ACT (RCRA)
ENACTED IN 1976
IMPLEMENTING REGULATIONS IN 1980
HAZARDOUS AND SOLID WASTE AMENDMENTS OF
1984
FEDERAL FACILITIES COMPLIANCE ACT OF 1992
18
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
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
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
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 (Chapter VII, 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
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
Hazardous Wastes
Are Solid Wastes
May be CHARACTERISTIC or LISTED Hazardous Wastes
Include Universal Wastes, but they are managed differently
24
IGNITABLE WASTES
Can create fires under certain conditions, are spontaneously combustible, or have a Flash Point <140 degrees F
Includes Ignitable Compressed Gas
EPA Waste Number D001
Examples: used solvents
26
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
EPA Waste Number DOO2
Examples: battery acids, lime
27
REACTIVE WASTES
Unstable under “normal”
conditions, causing
explosions, toxic fumes,
gases, or vapors when
heated, compressed, or
mixed with water
EPA Waste Number DOO3
Examples are lithium-sulfur
batteries and explosives
28
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)
EPA Waste Numbers D004-D043
Examples are metal-contaminated parts cleaning solutions, lead in paint scrapings
29
Let’s Review
True or False?
“Solid Waste” as defined under RCRA may be
a solid, liquid, or gas
It’s True
30
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
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
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
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 generator35
Generator Requirements
According to RCRA, all generators must characterize their waste streams, through Generator’s knowledge or MSDS
Laboratory Analysis
Identification as Listed Waste
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
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
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
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
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
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
Let’s Review
Hazardous Waste 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
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
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
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
Batteries
Batteries contain heavy metals such as mercury,
lead, cadmium, and nickel, which can contaminate
the environment when improperly disposed of.
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
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
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
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
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
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
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
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
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
Universal Wastes
Universal Waste (UW) regulations were passed to allow REDUCED regulatory requirements on some commonly generated hazardous wastes
Batteries
Lamps containing mercury
Mercury switches
Recalled pesticides
Universal Waste “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
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
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
UW Management Requirements for
Small & Large Quantity Handlers
Accumulation Times
Cannot be stored for longer than ONE YEAR
Must be able to demonstrate the length of time the UW
has been stored
Place start date on UW
Maintain a log
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
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
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
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
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
How Do Spills Happen?
Container failure (ruptures, leaks)
Transfer of materials (pouring, siphoning)
Tank overfill
Piping failure (ruptures, leaks)
Explosion or fire
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
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
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
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