Resource Conservation and Recovery Act (RCRA)

1 Resource Conservation and Recovery Act (RCRA) Resource Conservation and Recovery Act (RCRA) Lisa Environmental Protection Agency (EPA)Region 1 New EnglandLisa Environmental Protection Agency (EPA)Region 1 New EnglandMOST COMMON RCRA VIOLATIONS IN HEALTHCAREMOST COMMON RCRA VIOLATIONS MOST COMMON RCRA VIOLATIONS IN HEALTHCAREIN HEALTHCAREH azardous waste determinationsImproper disposalOpen containersUnmarked/unlabeled containersSatellite accumulationHazardous waste trainingContingency planUniversal WasteNote: Don t forget contractors and consultantsHazardous waste determinationsHazardous waste determinationsImproper disposalImproper disposalOpen containersOpen containersUnmarked/unlabeled containersUnmarked/unlabeled containersSatellite accumulationSatellite accumulationHazardous waste trainingHazardous waste trainingContingency planContingency planUniversal WasteUniversal WasteNote: Don t forget contractors and consultantsNote.

2 Don t forget contractors and consultantsRCRABASICSRCRABASICSRCRA Basics IRCRA Basics IHAZARDOUS WASTE DETERMINATIONS Generator s responsibilityannually or when process changes Process knowledge Analysis MSDS Expiration datesHAZARDOUS WASTE DETERMINATIONS Generator s responsibilityannually or when process changes Process knowledge Analysis MSDS Expiration datesRCRA Basics IRCRA Basics IHAZARDOUS WASTE DETERMINATIONS Process knowledge Analysis MSDS Expiration datesHAZARDOUS WASTE DETERMINATIONS Process knowledge Analysis MSDS Expiration datesRCRA Basics IIRCRA Basics IIWaste Activity NotificationWaste Activity NotificationRCRA Basics IIIRCRA Basics IIIGENERATOR CLASSIFICATION - VOLUME Large Quantity > 1000 kg Small Quantity 100kg 1000kg, < 1kg acute and no more than 1000kg at any time Conditionally Exempt < 100 kg, < 1kg acute and no more than 1000 kg at any timeGENERATOR CLASSIFICATION - VOLUME Large Quantity > 1000 kg Small Quantity 100kg 1000kg, < 1kg acute and no more than 1000kg at any time Conditionally Exempt < 100 kg, < 1kg acute and no more than 1000 kg at any timeRCRA Basics IIIRCRA Basics IIIGENERATOR CLASSIFICATION - TIME Large Quantity - 90 Days Small Quantity 180 Days Conditionally Exempt - no time limitGENERATOR CLASSIFICATION - TIME Large Quantity - 90 Days Small Quantity 180 Days Conditionally Exempt - no time limitRCRCA Basics IVRCRCA Basics IVContainer ManagementContainer ManagementRCRA Basics VRCRA Basics VSatellite vs.

3 Non-Satellite StorageSatellite vs. Non-Satellite StorageRCRA Basics VIRCRA Basics VISATELLITE STORAGE At or near point of generation Under the control of the operator of the process Less than 55-gallons of wastes -totalSATELLITE STORAGE At or near point of generation Under the control of the operator of the process Less than 55-gallons of wastes -totalRCRA Basics VIIRCRA Basics VIISATELLITE STORAGE Labeled Hazardous Waste and other words that describe contents Keep container closedSATELLITE STORAGE Labeled Hazardous Waste and other words that describe contents Keep container closedRCRA Basics VIIIRCRA Basics VIIICONTAINER MANAGEMENT Labeling ( hazardous waste and other words that describe contents) Dating Compatibility Aisle spaceCONTAINER MANAGEMENT Labeling ( hazardous waste and other words that describe contents)

4 Dating Compatibility Aisle spaceRCRA Basics IXRCRA Basics IXCONTAINER MANAGEMENT Condition of containers closed Ignitable waste special requirements Air emission standardsCONTAINER MANAGEMENT Condition of containers closed Ignitable waste special requirements Air emission standardsRCRA Basics XIIRCRA Basics XIIM anifesting WastesManifesting WastesManifesting WastesRCRA Basics XIIIRCRA Basics XIIICONTAINER STORAGE AREA INSPECTIONSThe owner or operator must inspect areas where containers are stored, at least weekly, looking for leaks and for deterioration caused by corrosion or other STORAGE AREA INSPECTIONSThe owner or operator must inspect areas where containers are stored, at least weekly, looking for leaks and for deterioration caused by corrosion or other Basics XVRCRA Basics XVHAZARDOUS WASTE TRAINING Initial training Annual refresher training Documentation Relevant to job duties performed Training program led by qualified staffHAZARDOUS WASTE TRAINING Initial training Annual refresher training Documentation Relevant to job duties performed Training program led by qualified staffRCRA Basics XVIRCRA Basics XVIHAZARDOUS WASTE TRAINING Job titles Job descriptions RCRA vs OSHAHAZARDOUS WASTE TRAINING Job titles Job descriptions RCRA vs OSHARCRA Basics XVIIRCRA Basics XVIICONTINGENCY PLAN Plan must be designed to minimize hazards to human health and the environment from fires, explosions, or release of hazardous waste or hazardous waste constituents.

5 Plan must be carried out PLAN Plan must be designed to minimize hazards to human health and the environment from fires, explosions, or release of hazardous waste or hazardous waste constituents. Plan must be carried out Basics XVIIIRCRA Basics XVIIICONTINGENCY PLAN Describe detailed response actions Arrangements with locals Emergency coordinators Emergency equipment Evacuation plans CONTINGENCY PLAN Describe detailed response actions Arrangements with locals Emergency coordinators Emergency equipment Evacuation plans RCRA Basics XIXRCRA Basics XIXPREPAREDNESS AND PREVENTION Alarm system Communication device Extinguishers Adequate water Aisle space Arrangements with localsPREPAREDNESS AND PREVENTION Alarm system Communication device Extinguishers Adequate water Aisle space Arrangements with localsRCRA Basics XXRCRA Basics XXPREPAREDNESS AND PREVENTIONF acilities must be maintained and operated to minimize the possibility of a fire.

6 Explosion or release of hazardous waste or hazardous AND PREVENTIONF acilities must be maintained and operated to minimize the possibility of a fire, explosion or release of hazardous waste or hazardous Basics XXIRCRA Basics XXIBIENNIAL REPORTA large quantity generator is required to submit a biennial report by March 1stof each even numbered year. This report summarizes waste activities during the previous REPORTA large quantity generator is required to submit a biennial report by March 1stof each even numbered year. This report summarizes waste activities during the previous Basics XXIIRCRA Basics XXIIUNIVERSAL WASTEU niversal wastes are widely generated and widely recycled hazardous wastes. Management standards for these wastes are reduced to facilitate their Waste need not be counted towards your monthly generation rateUNIVERSAL WASTEU niversal wastes are widely generated and widely recycled hazardous wastes.

7 Management standards for these wastes are reduced to facilitate their Waste need not be counted towards your monthly generation rateRCRA Basics XXIIIRCRA Basics XXIIIUNIVERSAL WASTE Batteries Pesticides Mercury containing thermostats Hazardous waste lamps Used electronicsUNIVERSAL WASTE Batteries Pesticides Mercury containing thermostats Hazardous waste lamps Used electronicsRCRA Basics XXIVRCRA Basics XXIVUNIVERSAL WASTE Containerization Label describing content Dating Training Record keepingUNIVERSAL WASTE Containerization Label describing content Dating Training Record keepingWHAT TO EXPECT DURING AN EPA RCRA INSPECTIONWHAT TO EXPECT DURING AN EPA WHAT TO EXPECT DURING AN EPA RCRA INSPECTIONRCRA INSPECTIONAUTHORITY42 USC Section 6927 (SWDA 3007)Gives EPA the authority to:Enter at reasonable times any place where hazardous wastes are or have been generated, stored, treated, disposed of or transported fromInspect and obtain samplesReview and copy records related to hazardous wasteAUTHORITYAUTHORITY42 USC Section 6927 (SWDA 3007)42 USC Section 6927 (SWDA 3007)Gives EPA the authority to:Gives EPA the authority to.

8 Enter at reasonable times any place where Enter at reasonable times any place where hazardous wastes are or have been generated, hazardous wastes are or have been generated, stored, treated, disposed of or transported fromstored, treated, disposed of or transported fromInspect and obtain samplesInspect and obtain samplesReview and copy records related to hazardous wasteReview and copy records related to hazardous wasteWHAT TO EXPECT DURING AN EPA RCRA INSPECTIONWHAT TO EXPECT DURING AN EPA WHAT TO EXPECT DURING AN EPA RCRA INSPECTIONRCRA INSPECTIONFEDERAL REGULATIONSFEDERAL REGULATIONSFEDERAL REGULATIONSSTATE REGULATIONSWHAT TO EXPECT DURING AN EPA RCRA INSPECTIONWHAT TO EXPECT DURING AN EPA WHAT TO EXPECT DURING AN EPA RCRA INSPECTIONRCRA INSPECTIONWHAT WE LOOK ATContainer managementEmergency planningTrainingOther recordsWHAT WE LOOK ATWHAT WE LOOK ATContainer managementContainer managementEmergency planningEmergency planningTrainingTrainingOther recordsOther recordsWHAT TO EXPECT DURING AN EPA RCRA INSPECTIONWHAT TO EXPECT DURING AN

9 EPA WHAT TO EXPECT DURING AN EPA RCRA INSPECTIONRCRA INSPECTIONWHEN WE ARRIVEIt will be a surprisePlan on spending a day to several days with usThere will be at least two of usMulti-media or notAn opening meeting you describe your facilityWHEN WE ARRIVEWHEN WE ARRIVEIt will be a surpriseIt will be a surprisePlan on spending a day to several days with Plan on spending a day to several days with ususThere will be at least two of usThere will be at least two of usMultiMulti--media or notmedia or notAn opening meeting An opening meeting you describe your you describe your facilityfacilityWHAT TO EXPECT DURING AN EPA RCRA INSPECTIONWHAT TO EXPECT DURING AN EPA WHAT TO EXPECT DURING AN EPA RCRA INSPECTIONRCRA INSPECTIONFACILITY TOURP hotos and lots of notesWill go to any and all areas of the siteWill look at chemical and waste storageFACILITY TOURFACILITY TOURP hotos and lots of notesPhotos and lots of notesWill go to any and all areas of the siteWill go to any and all areas of the siteWill look at chemical and waste storageWill look at chemical and waste storageWHAT TO EXPECT DURING AN EPA RCRA INSPECTIONWHAT TO EXPECT DURING AN EPA WHAT TO EXPECT DURING AN EPA RCRA INSPECTIONRCRA INSPECTIONRECORD REVIEWM anifestsWaste determination documentationTraining recordsContingency planBiennial reportRECORD REVIEWRECORD REVIEWM anifestsManifestsWaste determination documentationWaste determination documentationTraining recordsTraining recordsContingency planContingency planBiennial reportBiennial reportWHAT TO EXPECT DURING AN EPA RCRA INSPECTIONWHAT TO EXPECT DURING AN EPA WHAT TO EXPECT DURING AN EPA RCRA

10 INSPECTIONRCRA INSPECTIONOUTBRIEFP lease have all relevant people at this meetingDetailed review of areas of concernSummary of time frames and enforcement follow-upAsk questions and offer information on compliance have all relevant people at this Please have all relevant people at this meetingmeetingDetailed review of areas of concernDetailed review of areas of concernSummary of time frames and enforcement Summary of time frames and enforcement followfollow--upupAsk questions and offer information on Ask questions and offer information on compliance TO EXPECT DURING AN EPA RCRA INSPECTIONWHAT TO EXPECT DURING AN EPA WHAT TO EXPECT DURING AN EPA RCRA INSPECTIONRCRA INSPECTIONWHEN WE LEAVER eport and review findings with managementMay ask for more information (informally or information request letter)Prepare enforcement follow-upWHEN WE LEAVEWHEN WE LEAVER eport and review findings with Report and review findings with managementmanagementMay ask for more information May ask for more information (informally or information request (informally or information request letter)letter)Prepare enforcement followPrepare enforcement follow--upupWHAT TO EXPECT DURING AN EPA RCRA INSPECTIONWHAT TO EXPECT DURING AN EPA WHAT TO EXPECT DURING AN EPA RCRA INSPECTIONRCRA INSPECTIONTYPES OF ENFORCEMENTN otice of ViolationAdministrative Order with penalty (up to $ 32,500 per day per violation)Referral to the Department of Justice7003 Order for imminent/substantial endangermentReferral to State/other EPA program/other agencyCriminal referralNote.