1 RCRA Providence VAMC Hazardous Waste Management Program Research Lab Hazardous Waste Training 2008

2 RCRA Hazardous Waste Management  Why do we have a HW Program?  It is mandated by EPA, RI Dept. Environmental Management (RIDEM), and VHA  Safety of Patients, Staff, and Students  “Cradle to Grave” responsibility for our waste

3 RCRA Hazardous Waste Management  HW Program Elements 1)Employee Hazardous Waste Training 2)Hazardous Waste Identification 3)Hazardous Waste Storage  Accumulation Point (AP) Management  Satellite Accumulation Point (SAP) Management 4)Spill Response Procedures

4 RCRA Hazardous Waste Management EMPLOYEE TRAINING

5 RCRA Employee Training  HW training is required for personnel managing accumulation (AP) & initial accumulation points (IAP)  Initial HW training should occur within 6 months of a person assigned to a AP/IAP, then annual refresher.  It is NOT Health and Safety Training  It is NOT HAZMAT, HAZWOPER, or HAZCOM training

6 RCRA Employee Training  HW training will be done by a person trained in hazardous waste management (e.g. VAMC GEMS Coordinator)  Training must include Integrated Contingency Plan Procedures (e.g. Spill Response Procedures )  Training must include hazardous waste procedures relevant to the position they are employed

7 RCRA Hazardous Waste Management HAZARDOUS WASTE IDENTIFICATION

8 RCRA Hazardous Waste Identification  Definition of a Hazardous Waste :  Contaminated or spent chemicals that can no longer be used for their intended purpose, outdated or expired chemicals, and chemicals in poor containers (e.g. broken containers, missing labels, etc.).  Acutely toxic chemical listed by name in 40 CFR 261 (e.g. Sodium Azide; U and P Listed)  A chemical listed by name in 40 CFR 261 from a non-specific source (e.g. Methanol Solvent; F Listed)  Determined to exhibit a characteristic that the EPA has identified as making it a hazardous waste (e.g. isopropyl alcohol; D Listed)  Ignitable (<140 o F)  Corrosive (pH 12)  Reactive (water, oxidizer, friction, etc..)  Toxic

9 RCRA Hazardous Waste Identification  Examples of RESEARCH Hazardous Waste  Mixed Isopropyl Alcohol: (Ignitable, D001)  Trans Buffer (Toxic, F003 / Ignitable, D001)  X-Ray Fixer & Rinse-water (Toxic, D011)  X-Ray Developer (State Listed R006)  Hydrochloric Acid w/ Methanol (Corrosive, D002 / Ignitable, D001 / Toxic, F003)

10 RCRA Hazardous Waste Identification  Some wastes may not be “hazardous waste” but must be handled following hazardous waste procedures  Chemicals prohibited by the RI Narragansett Bay Commission for disposal to sanitary sewer  Universal Waste  Fluorescent Light Bulbs  Rechargeable Batteries  Used Oil

11 RCRA Hazardous Waste Identification  Universal Waste: A special class of hazardous waste  Batteries: Lead Acid, NiCad, Lithium, Silver Button.  Used lamps ( FLB’s, Sodium Lamps, etc.)  Mercury containing items, such as thermostats, thermometers, BP cuffs, some pressure gauges, some flow meters, etc

12 RCRA Universal Waste  Universal Waste must be properly labeled  “Universal Waste Batteries”  “Universal Waste Lamps”  Universal waste may not be accumulated for more than one year (Note: Hazardous Waste may not accumulate for more than 89 days)

13 RCRA Hazardous Waste Management HAZARDOUS WASTE STORAGE

14 RCRA Storage of Hazardous Waste  Initial Accumulation Points (IAP)  A storage location at or near the point of generation where hazardous waste is initially accumulated.  Limits on the amount of waste that can be accumulated at the IAP.  One container, up to 55 gallons per waste stream  No time limit on accumulation  Almost every Service has a SAP manager.

15 RCRA Storage of Hazardous Waste  Initial Accumulation Point Managers  Have control over the waste stored in their area  Responsible for weekly storage area inspections  Responsible for contacting the GEMS Coordinator if storage areas requires a waste pick-up  Responsible for training employees who place waste in their storage area.  RESEARCH IAP Managers are…  Julie Newton  Kerry LaPlante  C. McGeary

16 RCRA Initial Accumulation Points IAP-03, RM 123 Hoods IAP-14, RM 125 Waste Streams & , , Methanol & DMSO Developer, Fixer, Rinse water

17 RCRA Storage of Hazardous Waste IAP Requirements 1.Compatible Containers ( e.g. Acids in plastic/glass, Oils in metal containers) 2.Containers must remain closed when not adding waste

18 RCRA Storage of Hazardous Waste IAP Requirements 3. Labeling: All waste containers must be labeled appropriately with the words “Hazardous Waste” & “Contents of Container”  GEMS Coordinator can provide labels and containers

19 RCRA Storage of Hazardous Waste IAP Requirements 4. Secondary Containment for containers (protect floor drains)

20 RCRA Storage of Hazardous Waste IAP Requirements 5. Emergency Contact Information Posted 6. Have Spill Control Materials Available

21 RCRA Storage of Hazardous Waste IAP Requirements 7.Weekly Inspections  No leaks  No deterioration of containers  Containers closed  Everything properly labeled  Labels face forward  No incompatibles stored together  Date and time of inspection  Observations  Corrective actions taken  Full name of inspector (Initials or nicknames not acceptable)

22 RCRA Example of weekly inspection log

23 RCRA Accumulation Point Management  Room 135 & 227 – Flammable Storage  SAP containers are brought here when full  ASD placed on container  90 Day Accumulation  More than one container  Proper Segregation  Weekly Inspections  HW labeled completely filled out

24 RCRA Hazardous Waste Management  What happens to your waste after it is picked up?  We take it to our Central Accumulation Area  We conduct field tests for disposal characterization  We assign waste codes  We keep a weekly inventory and running inventory of the waste.  Waste must be off-site within 90 days.

25 RCRA Hazardous Waste Management Spill Response Procedures

26 RCRA Spill Response Procedures  Workers must be familiar will VAMC Integrated Contingency Plan (ICP)  Incidental spill V.S.  Non-incidental spill Report ALL spills to your supervisor, No matter what size it is

27 RCRA Incidental Spills  Small quantity (e.g. Amount you would use on a lab bench or slight spillage when transferring from one container to another in a shop  Can be cleaned without outside assistance  Always use the appropriate PPE when cleaning up spills  Spill clean-up material is hazardous waste

28 RCRA Non-Incidental spill  Amount greater than normal use  Outside resources needed due either to quantity or PPE limitations  Notify VA Police (x4999)  Process is identified in EOC Manual and Integrated Contingency Plan

29 RCRA Incidental Non-Incidental No Env. Exposure Env. exposure Spill Response Procedures

30 RCRA Major spill Spill Response Procedures

31 RCRA Hazardous Waste Management THE END  Questions?? Contact GEMS x2637

32 RCRA Training Certificate