RCRA: RESOURCE

CONSERVATION & RECOVERY ACT

Arizona Army National Guard

HAZARDOUS WASTE AWARENESSTraining Program

COURSE OBJECTIVES 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

WHAT 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)

WHAT IS A RCRA SOLID WASTE?

RCRA defines solid waste as: Garbage Refuse Sludge Industrial wastes Other discarded materials – solid, semi-solid,

liquid or gaseous

CONGRESSIONAL DEFINITION

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:

CRADLE-TO-GRAVE CONCEPT

WHAT KINDS OF WASTE DO WE HAVE?

Hazardous

WHY WE MANAGE 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

WHO MANAGES HW?

Everyonewho handles or works with

HAZARDOUS WASTE!

HOW DO WE MANAGE HW?

Comprehensive HW management includes:

Identification Disposal of waste

Classification Documentation

Accumulation Education of personnel

WHO TO CONTACT FOR HW HELP

For HW compliance guidance and assistance, contact: Pollution Prevention Dept – Environmental Office

Suzan Curtin – P2 Mgr – 602-629-4352 Randy Dozer – Env Health Spec – 602-319-0417 Kevin King – Haz Matl Spec – 602-540-6579

Environmental Office MAJ John Ladd – Env Program Mgr – 602-267-2742 Mary Westdyke – Env Administrative Asst – 602-629-4959

IDENTIFYING HAZARDOUS WASTE!

Listed by EPA Has at least one of these HW characteristics:

Ignitable Corrosive Reactive Toxic (TCLP)

Is a Universal Waste: Lamps Batteries

Pesticides Mercury-containing Equipment

Must meet at least one of these criteria:

EPA’S LISTED WASTESListed 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

WHAT ARE HW CHARACTERISTICS?

IGNITABLE:

<140oF

CORROSIVE:

pH is <2 or > 12.5

REACTIVE:

Violently reacts with H2O

TOXIC:

Exceeds limit of TCLP test

D001 D003

D002 D004 – D043

Do not mix hazardous wastes with non-hazardous wastes!

Before consolidating hazardous wastes, call the P2 Dept for guidance:

Randy Dozer – 602-319-0417

Suzan Curtin – 602-629-4352

WHAT ABOUT MIXING WASTES?

UNIVERSAL WASTE EPA promulgated – May 11, 1995

Promotes collection and recycling of HW known as Universal Wastes (UW):

Lamps

Batteries

Pesticides

Mercury-containing equipment

WHY UNIVERSAL WASTE? 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

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 HANDLER CLASSIFICATIONS

UNIVERSAL WASTE LABELING

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 contains3 items:

UNIVERSAL WASTE LABELING

Batteries: “Universal Waste – “Used Battery(ies)”

Pesticides: “Universal Waste – Pesticide(s)” or “Waste – Pesticide(s)”

Lamps: “Universal Waste – Lamp(s)” or “Used Lamp(s)”

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)”

MORE UNIVERSAL WASTE LABELING

STARTED OFF OK, BUT IS NOW UNACCEPTABLE. MUST WITHSTAND ELEMENTS OF WEATHER WHILE BEING STORED.

MISSING ACCUMULATION DATE; AVOID “BAD BULBS” COMMENTS; OPEN TOP

BATTERIES NOT PROPERLY LABELED; PLASTIC CONTAINER DOES NOT BELONG HERE.

Bulbs improperly managed

REVIEW HW PROCESS

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

PETROLEUM, OIL & LUBRICANTS

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:

EVEN POL DRIP CONTAINERS NEED LABELING!

EPA ID NUMBER

Provides a method to track HW Assigned per location, can’t be shared Defines HW generator status boundaries Assigned to HW transporters Must be entered on the HW manifest prior to

transportation and disposal

OUR CURRENT EPA ID NUMBERS

AZ4211890021 Papago Park

AZ5572890023 Silver Bell Army Heliport

AZ7213820635 Camp Navajo

AZ1572890027 Bellemont

AZ4572890024 Florence

AZ2572890026 Safford

AZ4572890057 Valencia

HW GENERATOR STATUSThree 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 CESQGsNOTE: Category applies to whole site; individual

shops or buildings are not classified separately

WHAT DEFINES 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

LQG REQUIREMENTS 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

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

WHAT DEFINES AN SQG?

SQG REQUIREMENTS 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

JOINT LQG & SQG REQUIREMENTS

LQGs / SQGs must:Have EPA ID numberAccumulate HW, as specified by regulationsIdentify, label and count HWComply 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

WHAT DEFINES A CESQG?Less than 100 kg (220 lbs) of HW per monthLess than 1 kg (2.2 lbs) of acutely HW per monthLimits 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

CESQG REQUIREMENTS

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)

EPISODIC HW GENERATION 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 levelon a permanent basis.

Pay attention to your generation of Hazardous Waste!!

CONTAINERS 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

CONTAINER INSPECTIONS

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!

LABELS AND MARKINGS

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

XXXYYYZZZ

WHAT IS A SATELLITE ACCUMULATION

POINT? 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

SAP REQUIREMENTS 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

SATELLITE ACCUMULATION POINT CHECKLIST

CENTRAL ACCUMULATION AREA (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

CAA REQUIREMENTS 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

CAA REQUIREMENTS (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”?

CAA EMERGENCY REQUIREMENTS

Must post next to telephone:Name and telephone number of

emergency coordinator and alternateLocation of fire extinguishers and spill

control material and fire alarm (if present)Telephone number of fire department,

unless facility has a direct alarm

HAZARDOUS WASTE MANIFESTS

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

WHAT IS A TSDF? TSDF – Treatment, Storage, Disposal Facility Two categories:

Permitted – HW disposal facilities, Camp Navajo’s 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)

HW SPILLS OR EMERGENCIES 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:

602-267-2742

EMERGENCY ASSISTANCE

If release is sizable or has unexpected reactions occurring, contact the

Environmental Office immediatelyfor assistance:

602-267-2742

KNOW YOUR HAZARDOUS WASTES

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?

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

CHECK OUT UPCOMING SLIDES

Spot poor waste management controls Discuss potential violations and risks Suggest corrective actions

What are your concerns in your work areas?

FULL DRIP PAN LEFT UNATTENDED IN PARKING LOT.

THIS TRAINING PROGRAM WAS PRESENTED TO YOU BY THE DEMA

ENVIRONMENTAL OFFICE.

OUR GOAL IS TO PROVIDE GUIDANCE AND SUPPORT TO PROMOTE YOUR HW

MANAGEMENT PROGRAM.

WE ARE AVAILABLE TO ANSWER QUESTIONS AND ADDRESS CONCERNS.

RANDY DOZER – 602-319-0417ENVIRONMENTAL HEALTH SPECIALIST

SUZAN CURTIN – 602-629-4352POLLUTION PREVENTION MANAGER