RCRA training

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

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3

Material or Waste?

• What is the difference between materials and wastes?

4

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)

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8

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

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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.

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Hazardous Waste Management

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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

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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

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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

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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

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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

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Hazardous Wastes

Are Solid Wastes

May be CHARACTERISTIC or LISTED Hazardous Wastes

Include Universal Wastes, but they are managed differently

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Hazardous Wastes:

Four types of Characteristic Wastes

IGNITABLE

CORROSIVE

REACTIVE

TOXIC

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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

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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

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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

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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

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Let’s Review

True or False?

“Solid Waste” as defined under RCRA may be

a solid, liquid, or gas

It’s True

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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

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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.

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HW Generator Requirements

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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)

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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

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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.

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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

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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

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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

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HW Generation Points

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HW Generation Point Sign

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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

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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

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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

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Wastes and How to Manage Them

Think about the wastes you generate at your facility

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Batteries

Batteries contain heavy metals such as mercury,

lead, cadmium, and nickel, which can contaminate

the environment when improperly disposed of.

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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.

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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.

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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.

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Management of Other Wastes

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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

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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”

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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.”

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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.”

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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.

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Universal Wastes

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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

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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

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Storage Items must be in

containers that are

structurally sound and

adequate to prevent

breakage

Containers must be

closed

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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

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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

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Waste Identification Exercise

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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?

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Que pasa?

?

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Que pasa?

?

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Que pasa?

?

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Que pasa?

?

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Que pasa?

?

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Que pasa?

?

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Que pasa?

?

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Que pasa?

?

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Spills

• What you need to know

–Prevent

–Prepare

–Respond

–Report

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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

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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)

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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

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How Do Spills Happen?

Container failure (ruptures, leaks)

Transfer of materials (pouring, siphoning)

Tank overfill

Piping failure (ruptures, leaks)

Explosion or fire

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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

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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

Spill

Reporting

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

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

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YOU ARE READY FOR THE TEST!

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