RCRA : R esource C onservation & R ecovery A ct

1. RCRA: Resource Conservation & Recovery Act Arizona Army National Guard HAZARDOUS WASTE AWARENESS Training Program

2. 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

3. 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)

4. RCRA defines solid waste as: Garbage Refuse Sludge Industrial wastes Other discarded materials – solid, semi-solid, liquid or gaseous What is a RCRA Solid Waste?

5. Congressional Definition Hazardous waste (HW) – solid waste, which because of its quantity, concentration, or physical, chemical, or infectious characteristics may: • 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

6. Cradle-to-Grave Concept

7. What Kinds of Waste Do We Have? Hazardous Recyclables Used Oil Medical Waste Regulated Waste Solid Waste

8. 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

9. Who Manages HW? Everyone who handles or works with HAZARDOUS WASTE!

10. How Do We Manage HW? Comprehensive HW management includes:

11. 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 – HazMatl Spec – 602-540-6579 • Environmental Office • MAJ John Ladd – Env Program Mgr – 602-267-2742 • Mary Westdyke – Env Administrative Asst – 602-629-4959

12. Identifying Hazardous Waste! Must meet at least one of these criteria: • 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

13. EPA’s Listed Wastes Listed 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

14. What Are HW Characteristics? REACTIVE: Violently reacts with H2O IGNITABLE: <140oF D001 D003 TOXIC: Exceeds limit of TCLP test CORROSIVE: pH is <2 or > 12.5 D004 – D043 D002

15. What About Mixing Wastes? 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

16. Universal Waste • EPA promulgated – May 11, 1995 • Promotes collection and recycling of HW known asUniversal Wastes (UW): • Lamps • Batteries • Pesticides • Mercury-containing equipment

17. 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

18. UW Handler Classifications • 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

19. Universal Waste Labeling Universal Waste labeling ALWAYS contains3 items: • The words “Universal Waste” • Name of Universal Waste • Accumulation Start DateNOTE: Universal waste can only remain on-site for 1 year maximum

20. 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)”

21. More Universal Waste Labeling • 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)”

22. Started off OK, but is now unacceptable. Must withstand elements of weather while being stored.

23. Missing Accumulation Date; Avoid “Bad Bulbs” comments; Open top

24. Batteries not properly labeled; plastic container does not belong here.

25. Bulbs improperly managed

26. Review HW Process Is material a solid waste? NO YES Material is not hazardous waste Is waste excluded from the definition of solid or hazardous waste? YES NO NO Waste is HAZARDOUS and subject to RCRA Subtitle C Is waste a listed, a characteristic or universal HW? YES YES Is waste delisted? NO

27. Petroleum, Oil & Lubricants POLs: • Are not hazardous wastes – do not mix any hazardous waste into them • Require specific wording on all waste POL containers, including tanks: USED OIL

28. Even POL Drip Containers Need Labeling!

29. 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

30. Our Current EPA ID Numbers AZ4211890021 Papago Park AZ5572890023 Silver Bell Army Heliport AZ7213820635 Camp Navajo AZ1572890027 Bellemont AZ4572890024 Florence AZ2572890026 Safford AZ4572890057 Valencia

31. HW Generator Status Three 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 CESQGs NOTE: Category applies to whole site; individual shops or buildings are not classified separately

32. 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

33. 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

34. What Defines an SQG? 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

35. 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

36. LQGs / SQGs must: Have EPA ID number Accumulate HW, as specified by regulations Identify, label and count HW Comply 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 Joint LQG & SQG Requirements

37. What Defines a CESQG? • Less than 100 kg (220 lbs) of HW per month • Less than 1 kg (2.2 lbs) of acutely HW per month • Limits 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

38. 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)

39. 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!!

40. 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

41. 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!

42. 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 XXX YYY ZZZ

43. 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

44. 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 maxNOTE: 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

45. Satellite Accumulation Point Checklist

46. 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

47. 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

48. 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”?

49. CAA Emergency Requirements • Must post next to telephone: • Name and telephone number of emergency coordinator and alternate • Location of fire extinguishers and spill control material and fire alarm (if present) • Telephone number of fire department, unless facility has a direct alarm

50. 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, TSDFNOTE: Only Randy, Suzan, Kevin and Hannah (Camp Navajo) are authorized to sign for AZARNG HW Manifests