United Stales
       Environmental Protector
Healthcare Environmental Assistance Resources
Pollution Prevention and Compliance Assistance
for Healthcare Facilities

-------
    imergency riannin
Community Right-To-Kno
    Understa
          ease
       ri
reauirem

-------
                    reciujrecJ  wrier.
            BfJKll GhlB
releases occur
Chemicals are stored on site above certain

thresholds
Chemicals are processed or otherwise used on
 • A   ^^^^H      ^^^^H •  d •    |  ||
                     holds

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         Releaiee Reporiinc
                       j       ^_>
• Accidental release reporting is required
  under:
• Section 304 of the Emergency Planning
  and Community Right To Know Act or
  EPCRA. as well as.         "^
J -S ^ CtJ D|M|JfiHJ]
  Environmental R
  ?irirl I imbilirv Anr n
TJHrh-jr
 MlilTi]
m

-------
                        JTV
                        J j j
. ..the regulation applies to any facility a
which a hazardous chemical is produce*
used or stored and at which there is a •
release of a reportable quantity of any
Extremely Hazardous SL

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This is a reference document which lists
  chemicals with their associated CERLCA
  and EPCRA reporting thresholds
It can be found on the web at:    •^••P"
http://yosemite.epa.gov/oswer/ceppoweb.nsf/
               ?OpenDocument&list°/c

-------
T r;
njnci arms re
                  38 JS
rii jjfpr
^ i -—*j j j ^-x ^>.
                 .esponse Center
 at 1-800-424-8802
 Call the State Emergency Responsi
 Commission or the SERC
 r
rig I DC
J J S^/  • ^_X ^>
           rtheLEPC

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	    	               nvironmental
  Conservation Hotline - the SERC in NYS:
             518-457-7362
New Jersey Department of Environmental
  Protection - the SERC in NJ:
              77-927-6
                artment of Environmental
        ion-  718-337-4357

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          -
    EI r  r\f-
            nveniory
            required by
Sections 311 and 312 of EPRCA and applies
  to
...any facility that is required to prepare or
  have available a Material Safety Data Sheet
     DS) for a hazardous chemical u
                                 (OSHA)
Occupational Safely and Hsa.

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  Substance list at 500 pounds or that
  material's specific Threshold Planning
  Quantity or TPQ, whichever is less
There are approximately 366 chemicals on the
   f Us

-------

       r irrai mciiiiv srors
                v_X
10,000 pounds of any hazardous
           chemical
A chemical is considered hazardous if it
          "*-  ftheO
nv one
D r I

-------
                    rv
                  Z Of nr Urlr-
Fire Hazard - includes: a flammable material,
  a combustible liquid, a pyrophoric material
  or an oxidizer                ^^  •>
S

udde
  explosive m
of Pressure - includes:
     md compressed gases

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  rbi^ird Catenori
  J J >_>J	1 ^>J J ^rfJ -~^X ^>J ^ -_»/ ^1 ^_X J J

o
            '\ A  r)'\*~) rvr r"
            \  \ .,  o \Z Of n
Reactive - includes: unstable reactive
  materials, organic peroxides, and water
  reactive materials
                   ealth
  sensitizer

-------
              /-vr
           z  Of n

Delayed (Chronic) Health Hazard - includes:
  carcinogens - as well as other chemicals
  with an adverse effect on a target organ that
  generally occurs as a results of long term
                ith a long
D
ure an

-------
                        rerr.
Section
copies of the MSDSs, or a list thereof, i
SERC, the LEPC and the Fire Department
with jurisdiction
Section 312 requires Hazardous Chemical
    ntory Forms (or Tier II forms) to the^~
    .C, LEPC and Fire Department with
jurisdiction          -    ^pp^r

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Section 311 requirements are a one time
  submittal - due within three months of the
  time the hazardous material is prese~"
  facility (in reportable amounts) and withi
 rthree months after the discovery of
  °:gnificant new information  concerning any
   »pect of the hazardous materic

-------
Section 312 requires an annual submittal of
  inventory forms (Tier II forms) and the
  information is due on March 1st for eac
  previous calendar year
Forms and  instructions are available on the
   eb at:
                   ov/oswer/G'
we
content/tier2,htm

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       lJ on s Trorn
xl ^1  * J '
   )
             of EPCR
                 tate government facilities
Any food, food additive, drug or cosmetic
regulated by the Food & Drug Administration
                isent;
    so that exposure to the
not occur under normal op
                           id in
  any
                                  does
                              onditions

-------
Exemptions rrorrj Ssarjon>
             of EPCRA
     substance use
or personal, family o
 ..ousehold purposes - or is present in the
 same form and concentration as a product
 packaged for consumer use   	
 \ny substance to the extent it is used in a
       1  ' '   -a hospital or other medicr
              e direct supervision of a
 technically qualified individual "^^

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Exemptions rrorrj Ssarjon
             of EPCR
 routine agricultural operations or is a
 fertilizer held for sale by a retailer to the
 ultimate consumer
  ny hazardous waste as such term is
               Jid Was
   ended by the Resource Conservation
 and Recovery Act of 1976 (RCRA)

-------
        me JT you nave c
n
Ellen Banner- EPA Region
EPCRA 302-312 Coordinate
732-321-4348

-------

-------

-------
    Clean Air Act
    Requirements
Impacting Hospita
U.S. Environmental Protection Agency
        Region II
       May 22, 2003

-------
->  NT
             rTi
           	I.
ring  Permit
           ting Permits


        gulation
•pr
  New Source Performance Standards
  Hazardous Air Pollutants
  Ozone Depleting Substance
  Risk Management Plans

-------
Title V
J
P
       to major sources
       5 TPY, VOC 25 TPY, S02 100 TPY, CO
      i PY, PM/PM10 100 TPY, HAPs 10/25 TPY
        ' permits
Must address all emission points at facility
Public participation
Fees based on tons of emissions
  -N0;<25
     00
-> rive year

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Title V  Permits
    ri
    orn
iance Issues:
   - Report;
            to EPA --quarterly, semiannual,
                   liance Certifications Incomplete
         :ertify compliance for each individual term or condition
        compliance status
        identify monitoring method(s) and other means used
        continuous or intermitten compliance
        identify alternative monitoring method(s) and/or
        alternative operating scenario(s) actually used

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                                   err
                      TJJI
-> Two JocsjJ hose,
-» Penalties fo.
  permit Eippii
      collected
 t submitting timely Title V
ions
        ,000 (Staten Island Hospital)
    $ 46,000 (NY Presbyterian Hospital)

-------
                   mr ^|B
                   P
                 ^^mfj^^f
                 Of)
permits
  quired to obtain sta
air emission sources
  vered by State regulations
  RACT for boilers
  Chemical/Solvent storage areas
  Fuel composition requirements

-------
I ^^r ^H
re
  New
rmance
        -applies to criteria pollutants
        I Emission Standards for
        >us Air Pollutants (NESHAPS) -
   pplies to hazardous pollutants
 Ozone Depleting Substances -CFCs
 Risk Management Plans

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Boilers
Multiple programs;
  New Source Perfor
             nd PM
                     iance Standards for
    NESHAPs for Hazardous Air Pollutants
    proposed on January 13, 2003
  State Programs
  - State Implementation Plans

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Boilers
     f~^>j
   - Size
                  uon.
       Unit (MMBtu/Hr)
      if Construction/Modification/Reconstruction
-» HospltaJ E
        oilers
   ustrial-Commercial-Institutional Steam
  nerating Units
40 CFR Part 60: Subparts Db or DC

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Larger" Boilers - Subpart Db
Construed
 prr;
         >n, Modification, or
       uction After June 19, 198
Design He
29 M\
        at Input Capacity Greater
       100 million BTU/hr)

-------
Small" Boilers - Subpart DC
 Reconsb
tion aft
ne 8, 1989
    i
       Heat Input Capacity:
     i = 2.9 MW (10 million BTU/hr) and
   < 29 MW (100 million BTU/hr)

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Boilers
yp
  -   e of F
itrogen Oxides (NOX) an
"- "atter(PM)
    I (coal, coal refuse, oil, woi
a parity of Unit
 Standards Expressed as Nanograms per
 Joule of Heat Input (Ib/million BTU)

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Boilers
  Perform HI rice TestJnci
  Emission
   -S02
     ipsiclty
Monitoring
• Record keeping and Reporting
  Other SIP Provisions for Sulfur Dioxide (S02)
  and Nitrogen Oxides (NOX)

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- Reporting I
raj lure co
n
    mtent
      city Monitors Not Installed/Not Working
  Exceed Allowable Steam Production
  Failure to Obtain Permits for Emergency
  Generators

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Non-compliance with
  Puerto Rico JvJecJic£)
               :enter
   ;; Subpart DC; fired on No. 6 Fuel Oil
     r was a new boiler, second one was
    *~\ i Wf\
  - 2 DOJJ

  - One DQJ
    rscc
nstructed.
     id not install opacity monitor; did not
        irmance test; did not monitor sulfur
     >ntent on as feed a basis.
  - Settled for $ 175,000

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  Natlc
nal Emission
ard for Hazardous Air
  Pollutant (NESHAP) 40 CFR Part
                                    vj
-> Work Practic
  DemoJlcjo
          o Re
     or Renovation
          During
        .ed Asbestos-Containing Material
  (RACM) Includes Friable and Non-Friable Forms

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Asbestos
 RerjovatJon/DemoJitJo
 DPT;
  --* ^_*' —* -

 Arrio
ne Types and
of Asbestos in
      Jotification to EPA
 Required if Exceed Certain
 Thresholds

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 Asbestos
-»  or  enovation
reec on
   t or
             u. Feet
                      i near
                                         --
                                      P'E
  Inc
    Description of Facility
    Methods Used to Remove
    Asbestos
    Procedures to Comply with
    Asbestos Control

-------
Asbestos
Kern
f'JEiteri
Demo
                           s-Contain
                         Renovation or
               nles;
   - c
     :egory 1 Nonfriable in Good Condition
   ncased in Concrete
   iategory II Nonfriable that Won't Become Friable
  During Project

Wet  Down or Other Emission Control
  Trained Personnel

-------
Asbestos
    ompliance Issues
    Inventory




    Work Practices / Management Issues



    Notification / Reporting




    Documentation / Recordkeeping
   - Training

-------
Hazardous Air  Pollutants
                   Poll
       imum Achievable Control Technology (MACT)
             ~"CFRPart63
Standards
    National Emission Standards for Hazardous Air
       utants (NESHAPs) 40 CFR Part 61
     ome applicable MACTS: Dry cleaners, EtO
    Sterilizer MACT, and Boilers

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 Hazardous Air Pollutants
J
•••       ••!
Compliance I


- JVJACT Applicable

-------
Ozone-Depleting Substances
->

  g
I I-;
               at 40 CrR
        Emissions of CFCs / Other Chemicals that
        rtospheric Ozone
  ndustrial and Comfort Cooling Equipment Containing
  '~r~:~ Brants
 Recycling Refrigerants
 Non-Refrigerant ODS

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Ozone-Depleting  Substa
                                      man
          e program kicks in
         s 35% of the total charge in a 12-month period
      r commercial (cold storage) or industrial process
    refrigeration
    exceeds 15% for appliances (air conditioners,
    •efrigerators, chillers, or freezers)
      Repairs --must be completed within 30
  days to ensure leak rate is below the above
  criteria, unless	

-------
Ozone-Depleting Substa
Retroj
tor
         o r
                  nent P1
                  iin 30 days, and sources have up to
            ce/retrofit unit
       ated copy of plan on-site
     refrigeration equipment with > 50 Ibs charge
     certificates of technicians
     service records/invoices of work performed
     documentation showing use of properly certified
     recovery equipment

-------
Ozone-Depleting Substances
                Compliance Issues:

                 - Responsibility: EHS or
                  Maintenance

                 - Contractor Considerations

                 - Proper Equipment and Personnel

-------
tcJ rices
                accidental releases of
               :an cause serious harm to
    public and the environment from
  ort-term exposures and to mitigate the
severity of releases that do occur/'

-------
Risk Management  Plans
         ons found at 40 CFR Part 68.
           ilities Submit Risk Management
           ie 21, 1999
    Disability Depends on Storage Thresholds
  for 140 Regulated Substances
  - 500 - 20,000 Ibs. for Acutely Toxic
  - 10,000 Ibs. for Flammables

-------
-> May affect Hospitals if they
   — n
ve refrigeration systems that have
      n 10,000 pounds of ammonia
     lore
               icting systems that use more
    than 2,500 pounds of chlorine

-------
 New nrn
is St
            JJ]
              [i
drruurri
- Sulfur DJOXJGJ
  Chloride
      on Monoxide, Dioxins
  PM, Opacity, Fugitive Fly
  Ash/Bottom Ash

-------
Incinerators
-» New Sources (Built afce.
                  6/20/9
   - Initial compile].
     after
start up
•p rp«
               y 3/16/98 or 180 days
-> Existing S
    urces (Built before 6/20/96)
     State Plan
      • Within 1 year of approval of State Plan (New York
       approved August 1999)

-------
  Incinerators
-> Federal Plan Published
  8/15/00 (effective cia.b
  62 Subpart J
                      9/14/00) --See 40 CFR Pa
->
Fed era J  Plan a
   ciri
 - Initial Compliance Test within 6 months of the compliance
  date (August 15, 2001)
Federal Rule in Place until State gets approval
Title 5 permits

-------
Incinerators
Thre?
                                   ,our o,
                  s/hr 0r4,000 Ibs/day
           > 200 and 500 Ibs/hr or 1,600-4,000 Ibs/day
           < 200 Ibs/hr or 1,600 Ibs/day or less
 man  Kural Incinerators Criteria

 - > 50 Miles from Standard Metropolitan Statistical Area
 - < 2000 Ib/wk

-------
  Incinerators

   onorng &  eporting
  Operator Training
       & Qualificati
-» Waste Me
nagement Plans
  (small, rural)
            or Existing Incin
  Siting Restrictions for New
  Incinerators

-------
Incinerators
  Compliance
   - GEM and COf
          estmg
    Monitoring, Recordkeeping and Reporting
    Synthetic Minor / Title V Issues

-------
Questions ???
    -> Ai
larish Patel
 ~ el.harish@epa.gov
  Compliance Branch
712) 637-4046
712) 637-3998 (Fax)

-------
   nnci re
peedon
            our Jvecl
            ^X ^>J J  J J ^—«< ^>.
"	
r
What to expect when an EPA
Inspector comes to your door
          John Gorman
          EPA Region 2
          212-637-4008
      gorman.john@epa.gov

-------
  1  J
    n
-> What i
      s
multi-media inspection';
What
        re the common environmental
        is at medical facilities?
 ow can medical facilities improve their
environmental performance?

-------
What is si Multi-Medis) Inspection
j JVJJVJT
  erivironr
 urns or
is an inspection by two or more
"""lental programs (e.g., air, water,
   js waste) conducted at the same
   within 6 weeks of each other.

-------
                             ecu on
 rnp;
 are targeted for MMIs based on a
   factors such as past compliance
 .omplaints, regional/national
s, significant environmental
 and high non-compliance rate in
Healthcare facilities are a R2 priority.

-------
        d Ooeratin
                    I . -' A
MultHX
->
Openin
Conduct
   osjrici
    of the day Review Meetings (optional)
       Meeting
Follow-up Letter
Enforcement if necessary

-------

-------

-------

-------

-------

-------
6
     Y
,n Inspector
io Loo
           ore
  Said housekeep

     p us vvcinc
  Knovvlec
  not
             personnel
    vailable
    irds not readily
     ible or organized
    .corts
Denial of Entry
  :jcce

-------
                I M^^H^M^H
                rrJ
                i ^).
       brcement A
Formal Enforcement Acti
                                        Hospitals
                                          480
                                           49
      36
11 ($1,523,613)
 9 ($642,612)
                                           39
                                 146 covering 563 facilities
                               ($26,829,489 for 123 resolved)
                                          1745

-------

-------
 nnyjror
            ensfic
Program
RCRA
Environmental Benefits from FY04 Disclosures
More than 233,582 Ibs/year of hazardous waste is now
being managed properly because hospitals have self-
disclosed violations and corrected mismanagement.
               At least 1,757,713 gallons of oil is now being managed
               properly.
               At least 772 residential units now in compliance with
               lead-based paint rules.
               At least 12,680 pounds of chlorofluorocarbons now being
               appropriately managed.
               At least 41 buildings now managing asbestos properly.

-------
^yscernic violations a£m»-
  Inadequate res
  equipment
  em
viroi
            d training to carry out
       mental activities;
  lited or no environmental compliance
accountability for individual departments,
laboratories, and staff;
Limited authority vested in environmental
compliance officials;  ^jjgggjjjjggjj^

-------
l~"\    '  ^~^
Root  Cause
  No dear environments)] -cornpljarM
  of-corn rn and;
                              e cnain-
 Scsjterec
  erivjj
        , incomplete, and missing
    onmental compliance documentation;
 complete institutional knowledge
regarding environmental regulatory
requirements; and
Broad use of hazardous materials when
effective substitutes exist

-------
r SEJ tncare Violation
              Breakout of Violations from Hospital Disclosures
       EPCRA Violations
           7%
CAA Violations
   18%
    CWA Violations
        4%
                                                TSCA Violations
                                             SDWA Violations
                                                 0%
            RCRA Violations
               70%

-------
                aste (40 CFR Parts 2
                              ionO
      ra cones
  Dental Clinic
  X-rays Units
  Nucleaii
Medicine Areas
      macy
• Maintenance Areas
• Physical therapy
• Underground Storage
  Tanks
                                  htm)
 aundry
Morgue
Operating Rooms
Nursing Units
Hazardous Waste Storage
Areas
Medical Technology Unit
Construction Areas

-------
        Breakout of RCRA Violations from Hospital Disclosures
                        UST 3%
   Generator
Requirements 6%
    Container
Management 29%
                ID of HW25%
   General Facility
   Standards 10%
        Accumulation Time
               1%
                           Manifest 5%
                                                Universal Waste
                                                    21%

-------
  r^ xJ I  ' I   •"  J IJ '   J III
-> Did  ins facility ids.
  waste?

-> How
             zardous waste does the
       generate on a monthly basis?
 .s the facility properly managing and
disposing of its  hazardous waste?
Is the facility storing hazardous materials
safely?

-------
-> Ars hospital staff
 hazardous waste
-> Is the ho
          management;
         repared for emergencies?
^^^1  ^^^^H


j hos
           ospital have required records?
      ie hospital's underground storage
 tanks have the required corrosion, spill
 and overfill protection or were closed
 properly'' mmammmmmmmmmmm

-------
                 aste
                     onm
  ornpl
-» Hazardous Waste G
-> Used OiJ and Urm
-> Undergr
       torage Tanks
ous Waste Treatment, Storage, an
3! Facilities
 : Regulated under Subtitle D of RCRA

 iv/compliance/resources/policies/incentives/aud

-------
ndZc.
Understanding t
for Small Business-
                                faste Rules: A Handbook
  Hazardou
  Gen
  vvvvvv,
               e Requirements for Large Quantity

           region02/waste/public/lqgpdf.pdf
EPA
,v\/\-
     .s Office of Underground Storage Tanks
     w.eDa.qov/swerustl/index.htm
  Healthcare Environmental Resource Center
  www.h2e-online.org/hazmat/pharma.html

-------
                            ion02
-> Air Conclitiarilng/Retrlgera tiar
  vyvvvvJep5iJgov/regior]02/cfc
-> Asbestc
  P..I
                              htm)
  Other v
  booths
     /asbestos
:mergency Generators
Waste Incinerators
. gov/ttn/atw/129/h m i wi/r i h m i wi. htm I
.g., degreasers, ETO sterilizers, s

-------
    SEJ
j j x^ >_>j
                 Breakout of CAA Violations from Hospital Disclosures
                          Asbestos 8%
                                                           SIP (including
                                                          MACT, NESHAPS,
                                                           & Title V) 41%
                 CFCs51%

-------
Water ReciuJcitlor
                s (40 CFR Parts 100-
                               2/ff/ca.
                                         F^P mff^f^
                                         ntrn
Wastewater Dischar
    NPDES: www.
    UIC:

->
  S
  orm WEite
                     jov/npdes
                     /ogwdw/uic.html
r Discharges
" ,epa.gov/npdes/home.cfm?program_id=6
Oil above ground and underground tanks
  wv.epa.gov/oilspill/index.htm
  vvv
Other (e.g. filtration plants)

-------
Healthcare C
j j ~^** >_>j j ^tj j -^* >_>j j -«^> ^_^ j

-------
               erne
(hctp://
         ww.epa.
-> Emergent
  Know (40 Cf	
  h tcp ;//yo3srnits, spa, c
                                  ca.htm)
                                    .ght to
             Planning and Commu.         	
              * 302, 355, 370, 372)
                 i .gov/oswer/CeppoWeb. nsf/content/E
                 cument
vvwv\
            (40 CFR 150-189)
      .epa.gov/pesticides/
,>CBs(40 CFR Part 761)
www.epa.gov/opptintr/pcb/
www.epa.gov/compliance/incentives/auditing/protocol.html

-------
  SEJ
J J X^*! >_>J
*^
ions

-------
rJ6:

-------
                           I
From 14
Ran I-
Violation
 ID of HW
 Universal Waste
 Container
 Management
 Labeling
 CFC Leak Detection
 Records
ntary Disclosures)
  Statute   Frequency
  RCRA    497
  RCRA
  RCRA
                                417
                                271
  RCRA    269
  CAA

-------
                                I
     From 14
                 ntary Disclosures)
Rank
  Nation
          .equipments
          lical Inventory
  9
Manifests
Statute
                   CM
                   EPCRA
                        CWA
RCRA
 10   Personnel Training    RCPxA
Frequency
        209
                           114

-------
Ran1

violation
  1; Detection
Requirements
Empty Containers
Asbestos
             Statute
                    EPCRA
                    RCRA
                    RCRA
             RCRA
             CAA
Frequency

-------
               Number Of Viol
    rrc
;cc)tute
jrii;
         Maximum Number of
             Violations
 S
         Average Number of
             Violations
 -TP
  v * I
 CM
 CWA
SDWA

-------
                         aior
From j--

-------
              talM
     r-1
is a set of management processes am
 1  ires that allows an organization to
   e environmental considerations into
   Jay decisions and practices. It provides
mework for managing environmental
I a|
  procedures triat aJ
  Integra
        el a
  responsJDJJ
• EPA Region 2's EMS Website
  www.eDa.aov/reaion02/ems

-------
I '   J      ^^^^P^^V I^^W iXB'M'M^' trr ^i^P^^B^^^
Environmental Auditmc,
-> EPA'

oluntary Audi
 A\udit Agn
    ments
 EPA Region 2's Auditing Website
         .gov/region02/capp/cip

-------
on
                   ^^^^^^^^^^^^^p
                     en
-> Hospitals for a Healthy E
      J                 j
-> nnyjro
  www, spa.g
               .org
      Ny Preferable Purchasing
     ipptintr/epp
      Region 2's P2 Healthcare Website
            v/region02/p2/hea Ith. htm
        	ental Self-Assessment for Health Care
  Facilities - NY Dept of Environmental Protection
  www.dec.state.ny.us/website/ppu/esahcf.pdf

-------
Jew
from New Jerse
           uccessful New Jersey D
       Compliance Inspection"
                   when an in
                          es at my
 Why
                o be prepared for the inspection?
    » should accompany the inspector on the inspection
   nat happens if an inspector finds a violation?
  /ill I get a penalty?
 What happens after the inspection?
 www.nj.gov/dep/enforcement/ezinspect-html

-------
                                         Intro
Introduction
                 EPA Region 2

-------
                                                                 Intro-1
For hospitals, it is most important to know your
generator status because permit requirements depend
on which type you are:
     Large Quantity Generator (LQG)
     Small Quantity Generator (SQG)
                     •
     Conditionally-Exempt Small Quantity Generator (CESQG)

 Your status depends on how much waste you
 generate.
•The first step in any regulatory process is to determine what is regulated. In the case of RCRA, defining the universe of regulated wastes is the first
 requirement. All other regulations flow from this definition. That is, activities, units, and people regulated under RCRA, depends upon whether
 hazardous wastes are being managed.
                                  EPA Region 2

-------
                                                   Intro-2
Common Hospital Hazardous Waste
Violations/Issues
     •  Labeling of hazardous waste (H W) not done or incorrect
     •  Not conducting proper weekly inspections of HW storage
        Improper disposal of chemotherapy drugs
                 .
        HW determinations not done or incorrect
        No or inadequate HW manifests
        Throwing HW down the drain
        Improper management of expired pharmaceuticals,
        paints, etc.
        (continued on next slide)
                          EPA Region 2

-------
                                                 Intro-3
Common Hospital Hazardous Waste
Violations/Issues,  continued
     •  Lack of contingency plan
     •  Lack of or inadequate training for employees in HW
        managemenl
     •  Failure to ensure that HW meets Land Disposal Restriction
     •  Failure to upgrade or close underground storage tanks
        (USTs) by 12/22/1998
     •  Improper consolidation of wastes from nearby facilities
                         EPA Region 2

-------
                                                                               Intro-4
Common  Errors Made in Waste

Identification                               ^^^^

 •   Waste generation process not described     ^f       ^^^^1
                                                           1 ft. + 1      1 meter
     Test methods not identified

 •   Sampling methods not specified               ^^^^^^^^^r

 •   Field and laboratory QA/QC not identified
 •   Proper conversion factors not used

 •   Representative sample not obtained
•We'll learn that wastes may be listed by their sources. Are the sources adequately described?
•Have the correct test methods been used? SW-846 provides the exact methods to be used by EPA, states and the regulated community.
•Similarly, EPA's Laboratory Method for Solid Waste (SW-846) describes the appropriate sampling methods to assure representativeness of the sample.
•Quality control/quality assurance is imperative. The laboratory testing the waste must maintain QA/QC to assure they properly analyze wastes.
 Similarly, field sampling can easily be contaminated by poor handling procedures.
•Finally, a VERY common mistake is the improper conversion of ug/1 to ppm. The order of magnitude difference can result in a misidentification of a
 waste which SHOULD be regulated. 1,000 ug/L = 1 ppm; whereas 1 mg/L = 1 ppm.



                                         EPA Region 2

-------
                                                    Intro-5
Common Errors Made in Waste
Identification (Cont'd)          ^^^^
 •  Failure to reevaluate after process     f    ^^^\
                                       1 ft. + 1   1 meter
    change
 •  Failure to properly evaluate newly       ^^^^^^^^P
    generated wastes
 •  Failure to evaluate all waste streams
 •  Failure to take advantage of variances, exemptions,
    or policies that could result in reduced regulatory
    requirements
                           EPA Region 2

-------
                                                                                 Intro-6
Decision Diagrams

 •   A - Defining Regulated Waste

 •   B - Recycling

 •   C - Small Quantity Generators
 •The most important tool you will get through this course is the set of three decision diagrams.
 •These were designed to help you walk through the regulations to ensure you identify all of the regulations which may apply.
 •They are extremely useful, regardless of your experience in the program.
 •Each section of the course relates back to the three diagrams.
 •Decision Diagrams B and C are, in fact, detailed elements of Decision Diagram A.


                                          EPA Region 2                                 7

-------
                              Intro-7
Diagram A
      EPA Region 2                    8

-------
                        Decision Diagram A:  Determination of Subtitle C
                                    Regulation Status of a Waste
                Decision Flow Chart
                                                                                    Intro-

                                                                       40 CFR Reference
Is the material a discarded
 material? (See Decision
      Diagram B)

        Not a solid waste
       Yes

                                                                            261.2
                                                                                                                       (1)
 Is the material excluded
    under §261.4(a)?
Yes
        Not a solid waste
       No

 261.4(a)
                                                                                                                       (2)
Is the material excluded by
 a variance granted under
  §§ 260.30 & 260.31?
Yes
        Not a solid waste
       No
/260.30
\260.31
                                                                                                                       (3)
    The material is a
     solid waste (1)
                                                                                                                       (4)
      (Continued)
                                        (1) For materials that are recycled, see Decision Diagram B.
                                                    EPA Region 2

-------
                                    Decision Diagram A:  Determination of Subtitle C
                                           Regulation Status of a Waste (Cont'd)
                            Decision Flow Chart
                                                                                                                Intro-9

                                                                                                   40 CFR Reference
                  (Continued)
                      1
            Is the solid waste excluded
             from consideration as a
             hazardous waste under
                  §261.4(b)?
                           Yes
        Not a hazardous waste
        (still subject to Subtitle
             D Control)
                                                                                                       <261.
4(b)
                   No
                                                                                                                                     (5)
      Yes
 Is the solid waste listed as a
hazardous waste (K, P, or U)?
                                                                                                                   <261, SubpartD
                    No
                                                                                                                                    (6)
            Is the solid waste derived from
              the treatment, storage, or
            disposal of a listed hazardous
                     waste?
                           No
                    Yes
       No
Is the solid waste pickle liquor
 sludge or waste from burning
  petroleum-based wastes?
Yes

                                                                             l261.3(c)(2)
                                                                             \261.6(a)(3)(v)-(ix)
                                                                                                                   <26l.
                                                                                                                                     (7)
(Continued)
                              (Continued) (Continued)
                                        SB
                                                                 EPA Region  2
                                                                                            10

-------
                                         Decision Diagram A:  Determination of Subtitle C
                                                Regulation Status of a Waste (Cont'd)
                                Decision Flow Chart
                                                                                                                       Intro-10

                                                                                                          40 CFR Reference
(Continued)
                                               (Continued)
                                  (Continued)
              Yes
        Yes
     Is the solid waste a mixture of
     a solid waste and a hazardous
     waste listed solely because it
       exhibits a characteristic?

Does the mixture continue to
exhibit the characteristic? (2)
                        No
              The mixture is not a hazardous
               waste (still subject to Subtitle
                       D control)
                                                   Yes
            Is the solid waste a
             mixture of a solid
             waste and a listed
             hazardous waste?

 Does the mixture consist of
 wastewater the discharge of
  which is regulated under
CWA (Section 402 or 307(b))
and certain hazardous wastes
identified in §261.3(a)(2)(iv)?

                                                                           Yes
                                                                                        No
                                                                                 Is the solid waste
                                                                               environmental media
                                                                               which contains listed
                                                                                 hazardous waste?
                                                                               /261.
                                                                                                                                   3(d)(2)
                                                                                                        Yes

                                                                                                                               261.3(a)(2)(iv)
                                                                                                                                                (8)
               Has the waste been delisted?
                      No
                     Yes
         The solid waste is not a
      hazardous waste (still subject to
        Subtitle D control and any
      applicable delisting conditions)
                                                                                                                             fcO.20
                                                                                                                             160.22
                                                                                                                                                (9)
                                                                                                                                                (10)
               Does the waste exhibit a characteristic? (3)
                  Yes
                                                      No
                                                                                                             /26L
                                                                                   Subpart C
            The waste is a hazardous waste
                     T
                 (Continued)
                                         (2) For any mixture containing Bevill wastes see §261.3(a)(2)(iii).
                                         (3) For any mixture containing Bevill wastes see §261.3(a)(2)(ii).
                                                        EPA Region  2

-------
                                       Decision Diagram A:  Determination of Subtitle  C
                                                        Regulation Status of Waste
                            Decision Flow Chart
                                                                                                                                         Intro-11

                                                                                                                          40 CFR Reference
            (Continued)
               1
   Is the hazardous waste recycled?
      (See Decision Diagram B)
             No I
                                    Yes
                                       The recyclable material may be
                                     determined not to be solid waste or
                                   regulated under Part 266 or subject to the
                                       full set of Subtitle C regulations
                                                                                        f26
                                                                                        ) 261.2(c),(d),(e)
                                                                                       ^ 261.6
                                                                                        VPart266
                                                                                                                                                                 (11)
 Is the hazardous waste generated by a
      small quantity generator?
     (See Decision Diagram C)
             No
                            Yes
The hazardous waste may be subject
 to limited regulation under §261.5
          or Part 262.
/261.5
 (Part 262
                                                                                                                                                                 (12)
Does the hazardous waste occur under any
  of the following Special Management
     Practices? Are the materials...
   - wastes that are generated and remain in a
  product or raw material storage tank, transport
     vehicle, or manufacturing process unit?
                                             Yes
                                          Has the storage tank or unit ceased
                                            to operate and remained out of
                                           operation for more than 90 days?
        - samples collected for the sole purpose of
     determining characteristics or composition which
       are managed as required in Section 261.4(d)
              while stored or transported?
                                           No
                                                                 Yes
                                       Yes
           Not subject to
        Subtitle C regulations
           - samples collected for the sole purpose of
            conducting treatability studies which are
        managed as required under Section 261.4(e) while
                    stored or transported?
                                                     Yes
                                             Yes
- samples undergoing treatability studies which
are managed as required under Section 261.4(f)?
                                                            Yes
               - residues remaining in an empty container are
               managed as required under Section 261.7(a)(i)?
                       - PCB-containing dielectric fluid or
                     electric equipment containing such fluid
                  regulated under TSCA (part 761) and fail the TC
                             (D018-D043 only)?	
                     No
                                                               Yes
                                          The waste is a regulated hazardous waste and is subject to the full
                                           set of RCRA Subtitle C requirements including land disposal
                                                          restrictions under Part 268
/261.4(c)


/261.4(d)


J261.4(e)

J261.4(f)

•J261.7


/261.8
                                                                           EPA Region 2
                                                                                                                                                   12

-------
                              Intro-12
Diagram B
      EPA Region 2                    13

-------
              Decision Diagram B: Determination of When a Hazardous Waste that
                             is Recycled is Subject to Subtitle C  Regulation
                   Decision Flow Chart
                                                                                          Intro-13
                                                                             40 CFR Reference
   Is the material excluded
     under 261.6(a)(3)?
   Yes
     Material is not subject to
           regulation

                                                                                  <261.
                                               6(a)(3)
                                                                                                                              (1)
                                                                                                                              (2)
   Is the material inherently
         waste-like?
   Yes
     Subject to full Subtitle C
            regulation
         No
                                                                                  <261.
                                               2(d)
   Is the material hazardous
       waste batteries.
  thermostats, or pesticides?
   Yes
         No
        May be able to follow Universal Waste Rule
     requirements. Otherwise handle as hazardous waste.
                                          J273
                                                                                                                              (3)
   Is the material used in a
     manner constituting
   	disposal?	
   Yes
         No
      Is the material a commercial
     chemical product that is listed
    under §261.33 and is produced
      for application to the land?
Yes
Material is not
 a solid waste

                                        Subject to regulation under
                                           Part 266, Subpart C
                                                                                 Yes
  Is 75% of the material
recycled in a calendar year?
No
Is the material excluded by a
variance under §260.30(a)?

       Yes
               Yes
  Is the material a commercial
  chemical product listed under
          §261.33?

                                                                       Practice is speculative
                                                                   accumulation and is subject to
                                                                      full Subtitle C regulation
                                                                                   ,261.2(c)(l)
                                                                                                              50 FR 14219
                                                                                                              261.6(a)(2)(i)
                                                                                                              -266, Subpart C

                                                                             261. l(c)
                                                                             261.2(
                                                                             260.30
                                                                                                                              (4)
       (Continued)
                                                        EPA Region 2
                                                                                                  14

-------
                  Decision Diagram B: Determination of When a Hazardous Waste that
                           is Recycled is Subject to Subtitle C Regulation (Cont'd)
                                                                                            Intro-14
                       Decision Flow Chart
                                                                                40 CFR Reference
      (Continued)

 Is the material burned for
energy recovery in a boiler
or industrial furnace that is
   not regulated under
 Subpart O of Part 264 or
265 or is the material used
   to produce a fuel or
contained in a fuel, unless
  this is its normal use?
       No
Yes
      (Continued)
Is the material used oil that
exhibits one or more of the
characteristics of hazardous
        waste?

        Is the material a commercial
        chemical product that is listed
        in §261.33 and produced to be
            burned as a fuel?
Yes
Subject to regulation under
   Part 266 Subpart E
                         Yes
      Material is not a
         solid waste
                                                                             266 Subpart D
                                                                             266 Subpart E
                                                                             261.2(c)(2)(i)(B)

                                   Material is subject to
                                  regulation under Part 266
                                        Subpart D
                                                           EPA Region 2
                                                                                                   15

-------
                   Decision Diagram B: Determination of When a Hazardous Waste that
                            is Recycled is Subject to Subtitle C Regulation (Cont'd)
                                                                                                     Intro-15
                       Decision Flow Chart
                                                                                        40 CFR Reference
       (Continued)
        No
 Is the material used or reused as
  an ingredient in an industrial
   process, or as an effective
   substitute for a commercial
product, without being reclaimed?
        No
             Yes
                     Material is not a solid waste
                                                                                              261.2(e)
                                                                                                                                (5)
  Is the material
 recycled by being
  returned to the
 original process
 from which it was
   generated?
     No
Yes
     (Continued)
 Is the material
reclaimed prior to
return to original
    process?

Yes
Is the reclamation process
 in closed-loop tanks and
   are requirements of
   §261.4(a)(8)met?
                                                Yes
       Is the material returned as a substitute
        for raw material feedstock and does
          the process use raw material as
              principle feedstocks?

                                                            Yes

  Is the material
  excluded by a
 variance granted
under §260.30(b)?
                                                           Yes
                                          Material is not a
                                            solid waste


                                                                       261.2(c)(3)
                                                                       261.2(e)(l)(
                                                                       261.4(a)(8)
                                                            EPA Region 2
                                                                                                            16

-------
                  Decision Diagram B:  Determination of When a Hazardous Waste that
                           is Recycled is Subject to Subtitle C Regulation (Cont'd)
                                                                                    Intro-16
                      Decision Flow Chart
                                                                        40 CFR Reference
      (Continued)
Is the material reclaimed?
      No
                        Yes
 Material is not recycled.
  Return to Diagram A.
Is the material excluded by a
  variance granted under
       §260.30(c)?

                               Is the material a characteristic
                                by-product or sludge, or a
                               commercial chemical product
                                  listed under §261.33?

                              Are precious metals reclaimed
                                   from the material?

                               Is the material spent lead-acid
                                       batteries?

                                Material is subject to full
                                  Subtitle C regulation
                          Yes
Subject to regulation under
   Part 266, Subpart F
 ^260.30^)
 |261.1(c)
<261.2(c)(3)
 l261.6(a)(2)(iv)
 V261.6(a)(2)(v)
                          Yes
Subject to regulation under
   Part 266, Subpart G
                                                          EPA Region 2
                                                                                           17

-------
                              Intro-17
Diagram C
      EPA Region 2                    18

-------
               Decision Diagram C:  Determination of Small Quantity Generator Status

                    Decision Flow Chart
            Intro-18

40 CFR Reference


Is the facility a potential
small quantity generator?
Yes
^

Is the hazardous waste
generated subject to
Subtitle C regulations?*
Yes
T

r
Is the hazardous waste
subject to substantive
requirements of Subtitle C?
Yesl





Subject to full Subtitle C
regulation.

The waste is not included in
quantity determination.


The waste is not included in
quantity determination.

<261
J261
<261
5(a)
5(c)*
5(c)
                                                                                                                               (1)
         (Continued)
Notes:
*Under 40 CFR 261.5(c), you can except hazardous waste that: (1) Is exempt from regulation under 40 CFR 261.4(c) through (f),
261.6(a)(3), 261.7(a)(l), or 261.8; or (2) Is managed immediately upon generation only in on-site elementary neutralization units,
wastewater treatment units, or totally enclosed treatment facilities as defined in 40 CFR 260.10; or (3) Is recycled, without prior
storage or accumulation, only in an on-site process subject to regulation under 40 CFR 261.6(c)(2); or (4) Is used oil managed under
the requirements of 40 CFR 261.6(a)(4) and 40 CFR part 279; or (5) Is spent lead-acid batteries managed under the requirements of
40 CFR part 266, subpart G; or (6) Is universal waste managed under 40 CFR 261.9 and 40 CFR part 273.
                                                          EPA Region 2
                    19

-------
                Decision Diagram C:  Determination of Small Quantity Generator Status (Cont'd)
                                                                                                                              Intro-19
                            Decision Flow Chart
                                                                  40 CFR Reference
                 (Continued)

         Is the hazardous waste:
         - removed from on-site storage and has
          been previously included in quantity
          determination;
         or
         - produced by on-site treatment
          (including reclamation) of waste already
          included in quantity determination;
         or
         - spent materials generated, reclaimed and
          subsequently reused on-site that have
          already been included in quantity
          determination?
                       No
Yes
 The waste is not included in
   quantity determination.

                                                                        261.5(d)
                                                                                                                                        (2)
    No
         Is the waste an acutely hazardous waste?
                      Yes
         Is the acute hazardous waste generated at
         quantities greater than:
         - 1 kg of acute hazardous waste per
           calendar month; or
         - 100 kg per calendar month of any
           residue or contaminated soil, waste or
           other debris resulting from clean-up of
           a spill of any acute hazardous waste?
Yes
Subject to Subtitle C
    regulation.

                                                                        ,261.5(e)
                       No
                      (Continued)
(Continued)
                   EPA Region 2
                                                                               20

-------
            Decision Diagram C: Determination of Small Quantity Generator Status (Cont'd)


                       Decision Flow Chart
                                                                                           Intro-20

                                                                               40 CFR Reference
(Continued)
 No
(Continued)
 No
                     Does generator comply with
                  requirements set forth in §261.5(f)?
                            Yes

                                   Subject to Subtitle C
                                       regulation

                                                                       261.5(f)
                  The waste is conditionally exempt
                                                                                                                                (3)
        Is the sum of wastes
       included in the quantity
     determination less than 100
      kg of non acute hazardous
      waste per calendar month?
            Yes

          Does the sum of the
         wastes equal between
          100 kg and 1000 kg
          per calendar month?
               Yes
The waste may be
 subject to special
requirements under
    Part 262.


                                                                       261.5(a)
                                       Subject to full
                                    Subtitle C regulation.
                                                                                                                                (4)
      Does generator at any time
     accumulate more than 1,000
       kg of hazardous waste?
     Yes
             No
 All of the accumulated wastes are
   subject to modified Part 262
regulations at the time accumulation
      first exceeds 1,000 kg.
                                                                                   /261.5(g)(2)
                                                                                   \262.34(d)
            (Continued)
                                                            EPA Region 2

-------
       Decision Diagram C: Determination of Small Quantity Generator Status (Cont'd)


                  Decision Flow Chart
                                                                                          Intro-21

                                                                             40 CFR Reference
        (Continued)
            I
Is the hazardous waste mixed
  with solid waste and the
resultant mixture exceeds the
    quantity limitations?

           Does the mixture
               exhibit a
             characteristic?
                   Yes
Subject to full
  Subtitle C
  regulation
                                                                       <261.f
5(h)
         No

                                        The waste is
                                        conditionally
                                          exempt
                                                                                                                              (5)
  Is the waste mixed with
 used oil and is the resultant
   mixture to be used for
     energy recovery?
Yes
        No
The mixture, in addition to any material
   produced from such a mixture by
processing, blending, or other treatment
 if also destined for energy recovery, is
subject to regulation under Subpart E of
             Part 266
                                                                                                                              (6)
Does generator comply with
  requirements set forth in
        §261.5(g)?

                               Subject to full
                            Subtitle C regulation
                                          S261.
                                                                            5(g)
        Yes
                                                                                                                              (7)
     The generator is a
 conditionally exempt small
quantity generator during the
 measured calendar month
                                                        EPA Region 2
                                                                                                 22

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-------
      ENERGY STAR
Recognition Opportunities
ENERGY STAR Awards
Activity Recognition
Web Site Directory Listings
Building Profiles/Success Stories

-------
   How to Communicate Your
 Partnership with ENERGY STAR
Inform existing and potential customers
Use ENERGY STAR Logos
Train staff

-------
  How to Communicate Your
Partnership with ENERGY STAR
 Marketing support
 Events/Conferences
 Press Releases

                          Ad*g value to ytx* foriness
                       Superior
                      performance

-------
    Use of ENERGY STAR Logos
    Partner logo
    Linkage Phrase logo
    Linkage Phrase and Partner Logos
    and Guidelines           	
                                    Money isn't att you're saving
'ENERGY STAR
k  PARTNER
www.energystar.gov

1-888-STAR-YES
                    Money Isn't All You're Saving
BBS-STAR-YES • www. energystar.t
  Ask About
  .ENERGY STAR
      Ask About
      .ENERGY STAR
                    www.cnergj'slar.gov  1-SSS-ST AR-YES

-------

    Sample Sector-Specific Value
              Statements
Office Buildings
•  Saving 30% of energy costs in a commercial
  office building is equivalent to increasing the
  net operating income by 5%, which would
  support a 5% increase in asset value.

Hotels
•  A 10% reduction in energy costs is equivalent
  to increasing Average Daily Room Rate by
  $0.62 for limited service hotels and $1.35 for
  full service hotels.

-------

   Sample Sector-Specific Value
              Statements
Supermarkets
•  For the average supermarket, reducing
  energy costs by 10% is equivalent to
  increasing sales per square foot by nearly
  $42.

Hospitals
•  Each dollar saved in energy cost is equivalent
  to generating new revenues of $20 for
  hospitals, or $10 for medical offices and
  nursing homes.

-------
  Putting it AM Toge
Join the Partnership
Train Staff
Inform Customers
Achieve sales goals by
 everaging ENERGY STAR

-------
Thank You and Aim for the Star!
          For more information visit:
            www.eneravstar.aov
        and click on "For Your Business"
       or call the ENERGY STAR Hotline at
             1-888-STAR-YES.

-------
The New SPCC Rule
      Overview
         SEPA
         Oil Spill
         Program
     U. S. EPA

     www.epa.gov/oilspill

-------
    2002 SPCC Rule
           (Finally!)
Publication Date:  July 17, 2002
Effective Date: August 16, 2002

-------
The New SPCC Rule
New format
New sections for different types of
facilities and new subparts for different
types of oils (petroleum and other oils,
animal fats and vegetable oils).

Incorporates the use of plain language.

-------
Elements of the New Rule
 "Should to shall to must."
   Clarification that the rule's
   requirements are mandatory.

-------
     Applicability Under New Rule


     General Applicability 112.1
\rn-j
—^    Now includes "using oil"
       (i.e. oil filled electrical
       equipment).

-------
Applicability Under New Rule

» Regulatory threshold:
  - Raises the threshold by eliminating
   the 660 gallon/single container
   criteria.
  - Now total >1,320 gallons
 Minimum container size:
  - Exempts containers less than 55
   gallons from capacity calculation

-------
New Exemptions in the Rule
  The rule exempts completely
  buried tanks that are subject to
  all technical requirements of the
  Underground Storage Tank rules
  at (40 CFR part 280 or 281 ).
  Some exceptions may apply.

-------
New Exemptions in the Rule
    A facility, or part, used
    exclusively for waste water
    treatment and not used for
    any other requirement of
    40 CFR Part 112.

-------
Elements of the New Rule
SPCC Plan Preparation -
  otherwise exempt facilities:


  EPA Regional Administrators have
  authority to require preparation of
  an SPCC Plan for otherwise exempt
  facilities on a case-by-case basis.

-------
Elements of the New Rule
  New Definitions Section 112.2

    « Facility
    « Bulk Storage Container
    « Breakout Tank
    « Storage Capacity
    « Alteration
    « Repair
    « Permanently Closed Container

-------
New Definitions in the Rule

Facility:
  Any mobile or fixed, onshore or
  offshore building, structure,
  installation, equipment, pipe, or
  pipeline used in oil well drilling
  operations, oil production, oil
  refining, oil storage, oil gathering, oil
  processing, oil transfer, oil
  distribution, and waste treatment, or
  in which oil is used... (may be as
  small as a piece of equipment or as
  large as a military base).

-------
  New Definitions in the Rule
Bulk Storage Container:

•  Any container used to store oil.
  Oil filled electrical, manufacturing or operational
  equipment not included in the definition.
  Therefore, they are not subject to the bulk
  storage requirements of the rule (containment,
  testing, and fail safe engineering)


  Bunkered Tanks, Completely Buried Tanks
  Partially Buried Tanks are considered above
  ground tanks.

-------
New Definitions in the Rule
 Breakout Tank:
  A container used to relieve surges in
  an oil pipeline system or to receive
  and store oil transported by a
  pipeline for reinjection and
  continued transportation by pipeline.


 Storage Capacity:
  Means the shell capacity.

-------
New Definitions in the Rule
Alteration:

  Any work on a container involving cutting,
  burning, welding, or heating operations
  that changes the physical dimensions or
  configuration of the container.
Repair:
  Any work necessary to maintain or restore
  a container to a condition suitable for safe
  operation, other than ordinary, day-to-day
  maintenance to maintain the functional
  integrity of the container and that does not
  weaken the container.

-------
New Definitions in the Rule
 Permanently closed containers:
  No sludge, no liquid, no piping
  connections, closed/locked valves
  and signs indicating closure date.

-------
Elements of the New Rule
  Section 112.3


  •  Timeframes for preparation and
    implementation.


  •  Must maintain copy of Plan at
    facility if attended 4 or more
    hours per day.


  •  Professional Engineer (P.E.)
    certification statement.

-------
Elements of the New Rule

•  P.E. must certify SPCC Plan is
  prepared in accordance with Part 112
  and must consider applicable industry
  standards.

•  The rule will allow a P.E.'s agent to
  conduct the site visit in place of the
  P.E., but the P.E. must review the
  agent's work and certify the Plan.

•  P.E. certification not required for non-
  technical amendments.

-------
Elements of the New Rule

 Section 112.4
 Submission of SPCC Plan to
  Regional Administrator:

 Whenever facility has discharged:
 • more than 1,000 gallons; or
 • more than 42 gallons in each of two
  discharges in  any 12-month period.

 RA may require  amendments after
 on-site review of Plan.

-------
       Elements of the New Rule

         • Provide same information as that
           provided to RA to the State
           agency in charge of oil pollution
           control activities in state in which
           facility is located.
^       • The State agency may then make
  *•        recommendations to the RA as to
           further procedures, methods,
           equipment or other requirements
           necessary to prevent or contain
           discharges of oil from the facility.

-------
Elements of the New Rule
Section 112.5
Amendment by Owner/Operator:


•  Review Plan at least once every 5
  years.


•  P.E. must certify only technical
  amendments.

-------
 Elements of the  New Rule

Section 112.7 General

  Requirements:

• New format:
  - Includes new sections for different types of
    facilities and new subparts for different types
    of oils (petroleum and other oils, animal fats
    and vegetable oils).


• Alternative formats for SPCC Plans:
  - Encourages an owner or operator to use an
    Integrated Contingency Plan (ICP) or a State
    Plan (requires a cross reference to sections).

-------
Elements of the New Rule
 Deviations:


   The rule will allow waivers for most
   provisions, provided the owner or
   operator explains the reasons for
   nonconformance in the Plan and
   provides equivalent environmental
   protection.
   (Not applicable to secondary
   containment)


   RA may not agree and require
   amendment of the Plan.

-------
Elements of the New Rule
 Facility Diagram:
   Required; must mark location and
   contents of each container
   (including exempt UST's and all
   piping).


 Business records:
   Allows an owner or operator to use
   "usual and customary" business
   records  as a record of tests and
   inspections.

-------
Elements of the New Rule
 Brittle fracture evaluation:
   •The rule requires evaluations for
   field-constructed aboveground
   storage containers undergoing
   repair, alteration, or change in
   service.

 Employee training:
   •Limits training requirements to
   oil- handling employees.

-------
Elements  of the New Rule

Section 112.8 - Onshore Facilities,
  excluding production facilities:


Allows NPDES records to be used to record
  stormwater bypass events.

Requires testing on regular schedule, or after
  material repairs, must combine visual with
  other methodology.

Requires buried piping to have protective
  wrapping, coating and cathodic protection
  if installed after 8/16/02.

-------
Elements of the New Rule
Section 112.9
Onshore Oil Production Facilities:


Allows NPDES records to be used to
  record stormwater bypass events.


Clarifies that all tank battery,
  separation and treating installations
  must have secondary containment
  for entire capacity of largest single
  container and sufficient freeboard to
  contain precipitation.

-------
Elements of the New Rule
 Section 112.12
 Requirements for Animal Fats, Oils and
  Greases;  Fish and Marine Mammal
  Oils; and  Vegetable Oils:


  Same as Section 112.8

-------
             Timeframes
        • The SPCC rule requires the owner or
 «,       operator of a facility existing before
~        August 16, 2002, to amend, if
         necessary, the SPCC Plan on or
         before August 17, 2004, and to
         implement the amended Plan by
         February 18, 2005.

-------
    Timeframes
The owner or operator of a facility
that becomes operational after
August 16, 2002 through February 18,
2005, must prepare and implement a
Plan on or before February 18, 2005.

The owner or operator of a facility
which becomes operational after
February 18, 2005, must prepare and
implement a Plan before beginning
operations.

-------
Web Sites
  Web Site for New Rule:
    EPA Web Sites
 www.eDa.gov/oilsmlI/sDccrule

-------
           EPA Hotlines
800-424-8802
               National Response
               Center (NRC): 800-424-8802
             j
For SPCC, FRP, & OPA
Information: 800-424-9346
             j
NCR Product Schedule
Information: 202-260-2342

-------
EPA Contacts
  Christopher Jimenez
      732-906-6847
jimenez.christopher@epa.gov
    Michelle Rogow
      415-972-3082
  rogow.michelle@epa.gov
      Peter Reich
      415-972-3052
    reich.peter@epa.gov

-------
    QUESTIONS ???
           &EPA
           Oil Spill
           Program
         Thank you

U.S. Environmental Protection Agency

-------
           Compliance
      Initiative
     ,g Limited Resources to
Obtain Better Compliance
     Region 2 Healthcare Compliance
          Initiative

-------
^^™^l    I   ^^^    x^^    ^ff^^^B f'^r      ' t  ^HP *~  P ^TT^B
Goals For CornnljEjnce Initiative
~> Impro
   iifety
  faciJitie:
            environmenta comlem
            rn
  -> Change
   erivironrnen
           ie culture to one in which
             ':al compliance is a priority.
    sure compliance of entire sector; not
  ust those reached through inspections.
  Ensure continued compliance by
  implementing permanent changes.
              Region 2 Healthcare Compliance
                   Initiative

-------

-------
Jv oDJtorjDci  &  I ne'er
J J N—X J J J ^i •—X J I J J -^< I  >»-> -_  __i J J •«-* ^^ J
ornpJiar
acrarr
                               10 ($1,289, 913)
                                 8 ($557,612)
                      117 covering 452 facilities ($9,739,076
                               for 56 resolved)
                                   1100+

-------

-------
Environmental Benefits from FY04 Disclosures
More than 11,660 Ibs/year of hazardous waste is now being
managed properly because hospitals have self-disclosed
violations and corrected mismanagement.
At least 80,930 gallons of oil is now being managed properly.
At least 341 residential units now in compliance with lead-based
paint rules.
At least 2100 pounds of chlorofluorocarbons now being
appropriately managed.
        Region 2 Healthcare Compliance
                 Initiative

-------
^yscernic violations a£m»-
  Inadequate res
  equipment
  em
viroi
             d training to carry out
       mental activities;
   lited or no environmental compliance
accountability for individual departments,
laboratories, and staff;
Limited authority vested in environmental
compliance officials;  ^jjgggjjjjggjj^
          Region 2 Healthcare Compliance
               Initiative

-------
l~"\    '  ^~^
Root Cause
  No dear environments)] -cornpljarM
  of-corn rn and;
                               e cnain-
  Scsjterec
  envjj
         , incomplete, and missing
    onmental compliance documentation;
  complete institutional knowledge
regarding environmental regulatory
requirements; and
Broad use of hazardous materials when
effective substitutes exist
              Region 2 Healthcare Compliance
                  Initiative

-------
r~"J    J     /^^^PP^"
Finding  Corr
                            irorrricjuc
          iut what listings EKA nas ror your
         or to look up your TSD:
         facts: http://www.epa.gov/envi.
         ement & compliance history online:
       >://www.epa.gov/echo/
     rind P2 ideas and other references:
  -http://www.epa.gov/region2/p2/health.htm
facility/
- nnvirc
- Enforc
  hccr
               Region 2 Healthcare Compliance
                    Initiative

-------
6
       Y
,n Inspector
io Loo
-> Bad bouse]'
j KPPQ us
  J - ^J ~^> j_X _
-------
r SEJ tncare Violation
-------
                             ion02
   •oilers/.
    edJCEJ
                                        htm)
-> Air Conditioning/RefrigerEitior
  ritcpV/yvvvvv.epELgoy/rsgiorjr
-> Asbestc
                .gov/asbestos
         mergency Generators
        Waste Incinerators
http://www.epa.gov/ttn/atw/129/hmiwi/rihmiwi.htm
  Other (e.g., degreasers, ETO sterilizers, spray
  booths)
                 Region 2 Healthcare Compliance
                       Initiative
-------
Air Cornpliar.
-> Failure to use properly trained and accredited
  asbestos personnel, •
           notify EPA of asbestos remove'
          and keep required
              m/recordkeeping.
       •e to properly dispose of asbestos debris.
       •e to close lids on parts washers when not
-» FajJure cc
  project
  rlnrurrialilBlilg
-» Faiiu
  Failure to properly handle CFCs and records.
  Failure to include ETO sterilizer, spray paint
  booth, and parts degreaser in air permit.
                Region 2 Healthcare Compliance
                      Initiative
-------
  SEJ
j  j x^ >_>j
-------
  07
"(A) a
                 or.
rrp-
stores/ treats/ iranspq
otherwise haric
waste;
           entry:  ...Any person who generates,
                     ts, disposes of, or
                   . . las handled hazardous
              .on request of any officer,
        ie or representative of the environmental
protection agency...Or...Of a state having an
authorized hazardous waste program, furnish
information relating to such wastes and permit
such person at all reasonable times to have
access to, and to copy all records relating to
SUCh WaSteS."  ^^Hem^c™****

-------
                 ion Authorit
                    27 (
                       es or representatives
        ameers, em p.
are authorized
      enter at reasonable times any
          nt or other place where hazardous
         : or have been generated, stored,
    .ed, disposed of, or transported from;
(2) to inspect and obtain samples from any
person of any such wastes and samples of any
containers or labeling for such wastes."
              Region 2 Healthcare Compliance
                   Initiative
-------
                   on
                                rpr
  Tea
      ude one or two
rs...or may be as big as 4-6 for a
:ility (or more for a "multi-media
• "Credentials" will be presented by the
  inspector upon entry/introduction. (Note
  that they must remain in the inspector's
  possession and may not be photocopied.)
               Region 2 Healthcare Compliance
                    Initiative
-------
                 ction
f X~^l   ^B
(Com
                   are
-> Review or storac
                _**
  areas/ waste-genera
  docks/ dump
ie accurnuJ
                     :mg activities, loading
                  , material/product storage, etc
           je the areas that you consider HW
           others you may not think of as such.
  Review of paperwork (manifests, waste ID,
  training records, MSDS forms, etc.).
  Close-out briefing.
               Region 2 Healthcare Compliance
                     Initiative
-------
RCR
J _ "--^.X J  •—/
(If There Are Viols
~> enforce
  site,
-> Follow-
     nt decisions are not made on-
  Enforcer
    3 request for information (RCRA
) is common.
    lent may include:
   V-
    ** Administrative complaint - with
    penalty (up to $32,500/day).
             Region 2 Healthcare Compliance
                  Initiative
-------
          rce
-> Enforcement, ir n
  -Civil jur
                cessary, may include:
        icial referral to DOJ
                    ^•^•^H
     order for imminent/substantial
endangerment.
Referral to another EPA/state program
Criminal referral.
           Region 2 Healthcare Compliance
                Initiative
-------
Hazardous vva
the r
Waste i
      ital in both expected and unexpected areas.
     lentification and knowledge of hazardous waste
     nents is important in all areas of the hospital.
     3ll technicians in waste determination/management.
Explain waste management procedures to all personnel who may
generate hazardous waste.
Ensure that all technicians and generators know who to call for
assistance and further information.
               Region 2 Healthcare Compliance
                      Initiative
-------
  OCllfJ
  scussor
new
        procedures;  itwil
inspections and help in training
 and failure to document the
termination may be a violation of
professional societies.
             Region 2 Healthcare Compliance
                  Initiative
-------
RCRA  Comment
                          onunuec.
-> Hospitals are responsible not only for the acti
     r*     II  i I     i .  r" f I  i       |   I
  performed oy crieir
  respon
  contra
  time on-sj
  part
    pr
       tors/consultants, whether they are full-
       i-site contractors, managing wastes as
     f equipment maintenance contracts, or
     ically hired for waste management
,  jvities.
Always anticipate an inspection by regulators ~
perform self-audits, keep records organized and
accessible,  and ensure that good operating
procedures are not just implemented, but also
maintained.
               Region 2 Healthcare Compliance
                     Initiative
-------
                aste (40 CFR Parts 2
                               ionO
       ra cones
  Dental Clinic
  X-rays Units
  Nucleai
Medicine Areas
      macy
• Maintenance Areas
• Physical therapy
• Underground Storage
  Tanks
                                   htm)
 aundry
Morgue
Operating Rooms
Nursing Units
Hazardous Waste Storage
Areas
Medical Technology Unit
Construction Areas
                  Region 2 Healthcare Compliance
                        Initiative
-------
  r^ xJ  I ' I   •"  J IJ '   J III
-> Did ins facility ids.
  waste?

-> How
              zardous waste does the
       generate on a monthly basis?
 .s the facility properly managing and
disposing of its hazardous waste?
Is the facility storing hazardous materials
safely?
             Region 2 Healthcare Compliance
                  Initiative
-------
-> Ars hospital staff
  hazardous waste
-> Is the ho
           management;
          repared for emergencies?
^^^1  ^^^^H


j hos
            ospital have required records?
      ie hospital's underground storage
 tanks have the required corrosion, spill
 and overfill protection or were closed
 properly'' mmammmmmmmmmmm
       Region 2 Healthcare Compliance
            Initiative
-------
               veer
               J •*- _r-J ^ _r-J J K'J
        ons
muianon areas
f HW
          er labeling of HW containers
        itainers of HW
      Correct HW manifests
Improper disposal of HW (e.g., throw
fluorescent light bulbs and paints in trash,
lab chemicals down drain)
             Region 2 Healthcare Compliance
                  Initiative
-------
            management training o
-> LclCK Of rJ
  employ
-> Treating
          W without a permit
   k of RCRA contingency plan
   T control equipment not readily
accessible
Failure to make HW determinations
             Region 2 Healthcare Compliance
                  Initiative
-------
                          meets Lan
Disn
estrictions
          upgrade/close underground
        canks (USTs) by 12/22/98
Malfunctioning leak detection systems on
USTs
             Region 2 Healthcare Compliance
                  Initiative
-------
                  aste
                    onm
  ornpl
-> Hazardous Wast
-> Used 01J
  Uric]
ind Universal Waste Generators
                     -
               . ste Treatment, Storage, and
           Facilities
• Facilities Regulated under Subtitle D of RCRA
www.epa.gov/compliance/incentives/auditing/protocol.html
                 Region 2 Healthcare Compliance
                       Initiative
-------
-» Understanding t
    andbook fo
                            ules: A
      nail Businesses
epa.gov/region02/waste/public/sqg_pdf.pdf
               /aste Requirements for Large
      ntity Generators
         ww.epa.gov/region02/waste/public/lqgpdf.pdf
  EPA's Office of Underground Storage Tanks
  http://www.epa.gov/swerustl/index.htm
                 Region 2 Healthcare Compliance
                       Initiative
-------
-------
             ions (40 CFR Parts 100-13
  Waste water DischarcjS
  NPDES: htrpV/y
  PretreEitrnerit; beep:/
  UIC; httpV/vvvvvv.ep
           .gov/npdes
     cfpub.epa.gov/npdes/home.cfm?program_id=3
        .gov/ogwdw/uic.html
-» Storm vv£ji
:r Discharges
   j.gov/npdes/home.cfm?program_id=6
    il above ground and underground tanks
    tp://www.epa.gov/oilspill/index.htm

    ther (e.g. filtration plants)
                  Region 2 Healthcare Compliance
                        Initiative
-------
Water Compliance
  No permit fo
            wastewater discharges
            I with permit conditions
     idequate secondary containment of
     ge tanks/containers
 o SPCC plan
Floor drains
  Not compJyin
  No/in
             Region 2 Healthcare Compliance
                  Initiative
-------
Healthcare C
j j ~^** >_>j j ^tj j -^* >_>j j -«^> ^_^ j
-------
               erne
        ww.epa.
Know (4
     WWW
   Planning and Commu,
   FR 302, 355, 370, 372)
        fswercepp/crtk. html

s (40 CFR 150-189)
       v/pesticides/
                          ca.htm)
                                     ight to
PCBs (40 CFR Part 761)
    //www.epa.gov/opptintr/pcb/

        iv/compliance/incentives/auditing/protocol.html
              Region 2 Healthcare Compliance
                    Initiative
-------
  SEJ
J J X^*! >_>J
*^
ions
-------
r ea  tnccirs  EPC
J  J N^ ^J J ^| J J N^rfl ^>J J  -_*(  	1 J  X_^ J
    T ^^P"
D anon
          Breakout of EPCRA Violations from Hospital Disclosures
              MSDS
              38%
                                           Chemical
                                           Inventory
                                             62%
                  Emergency
                  Planning
                    0%
                   Region 2 Healthcare Compliance
                          Initiative
-------
              talM
  CJ'O
is a set of management processes am
  1 ires that allows an organization to
   e environmental considerations into
   Jay decisions and practices. It provides
mework for managing environmental
  procedures mat aJ
  Integra
  dciy-to-cia
     ipori:
• EPA Region 2's EMS Website
  http://www.epa.gov/region02/ems
               Region 2 Healthcare Compliance
                     Initiative
-------
1^^™"    —           I
I       ^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^H ^^^r
Environment^
^^-^
r
                            ^^^^
                            r
       \
         oluntary Audi
J AunJT AcirB:
  j \ _j j _j j A —-1 j -»_^
             ments
      Region 2's Auditing Website
      """ vw.epa.gov/region02/capp/cip
              Region 2 Healthcare Compliance
                   Initiative
-------
         W^^W^^H
         on
yen
-> Hospitals for Ei Healthy Envlronm
            lki 6-orilln6.org
-> Enviro
               i.gov/opptintr/epp
       Region 2's P2 Healthcare Website
       '  ww.epa.gov/region02/p2/health.htm

        ....nental Self-Assessment for Health Care
  Facilities - NY Dept of Environmental Protection
  http://www.dec.state.ny.us/website/ppu/esahcf.pdf
                 Region 2 Healthcare Compliance
                       Initiative
-------
     Understanding the
     Hazardous Waste
     Rules
     Guidance for Hospital
     Environmental Health &
     Safety Professionals
Hospital Compliance Initiative
  RCRA Requirements
-------
Introduction
  What is hazardous waste?
  Typical healthcare hazardous wastes
  Requirements for CE-small quantity generators
  Requirements for small quantity generators
            Hospital Compliance Initiative
               RCRA Requirements
-------
Introduction
  Summary of additional requirements for large quantity
  generators
  Treatment, storage, and disposal facilities
  Universal waste requirements
  Description of a hazardous waste inspection
  Contact information
             Hospital Compliance Initiative
                RCRA Requirements
-------
What Is RCRA?
   Resource Conservation and Recovery Act
   RCRA's goals:
   - Protect human health and the environment from the hazards
     posed by waste disposal
   - Conserve energy and natural resources through waste
     recycling and recovery
   - Reduce or eliminate the amount of waste generated, including
     hazardous waste
   - Ensure that wastes are managed in an environmentally safe
     manner

              Hospital Compliance Initiative
                 RCRA Requirements
-------
What Is RCRA?
  RCRA Subtitle C - hazardous waste
  management program
  - Safe management of hazardous waste from
    generation to disposal
  RCRA Subtitle D - solid waste management
  RCRA Subtitle I - underground storage tanks
           Hospital Compliance Initiative
             RCRA Requirements
-------
What Is RCRA?
                       RCRA Hazardous Waste
                         Regulations, 40 CFR
           Hospital Compliance Initiative
              RCRA Requirements
-------
What Is RCRA?
  Part 260 - Hazardous Waste Management
  System: General
  Part 261 - Identification and Listing of
  Hazardous Waste
  Part 262 - Standards Applicable to Generators
  of Hazardous Waste
  Part 263 - Standards Applicable to
  Transporters of Hazardous Waste
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What Is RCRA?
  Part 264 - Standards for Owners and
  Operators of Hazardous Waste Treatment,
  Storage, and Disposal Facilities
  Part 265 - Interim Status Standards for Owners
  and Operators of Hazardous Waste Treatment,
  Storage, and Disposal Facilities
  Part 266 - Standards for the Management of
  Specific Hazardous Wastes and Specific Types
  of Hazardous Waste Management Facilities
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What Is RCRA?
  Part 268 - Land Disposal Restrictions
  Part 270 - EPA Administered Permit Programs:
  The Hazardous Waste Permit Program
  Part 271 - Requirements for Authorization of
  State Hazardous Waste Programs
  Part 272 - Approved State Hazardous Waste
  Management Programs
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What Is RCRA?
  Part 273 - Standards for Universal Waste
  Management
  Part 279 - Standards for the Management of
  Used Oil
  Part 280 - Technical Standards and Corrective
  Action Requirements for Owners and
  Operators of Underground Storage Tanks
  (UST)
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What Is RCRA?
  Part 281 - Approval of State Underground
  Storage Tank Programs
  Part 282 - Approved Underground Storage
  Tank Programs
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What Is Hazardous Waste?
  First determine if it is a solid waste
  Solid Waste: Any discarded solid, liquid, or contained
  gaseous material that is:
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What Is Hazardous Waste?
  Abandoned
  Disposed of
  Burned
  Incinerated
  Recycled
  Inherently waste-like
-40CFRPart261.2(d)
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 What Is  Hazardous Waste?
 Is material abandoned
    or inherently
  "waste-like" (solid
     waste)?
  Yes
the definition of solid or
  hazardous waste?
No
 No
  No
 characteristic
hazardous waste?
                 Yes
             MATERIAL IS NOf
               SUBJECT TO
            HAZARDOUS WAST
              REGULATIONS
                RE3LLAT1CNS
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What Is Hazardous  Waste?
   Is waste recycled by being:
   1) Used as an ingredient;
   2) Used as a product substitute;
   3) Returned to the production process?
No
WASTE IS A SOLID
     WAST"3
   Js recycled waste:
   1) Used in a manner constituting disposal;
   2) Burned for energy recovery, used to produce a
   fuel, or contained in fuels;
   3) Accumulated speculatively; or
   4) A dioxin-containing waste considered inherently
   waste-like?
 No
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What Is Hazardous Waste?
  If it is a solid waste, then is it a hazardous waste (40
  CFR Part 261)?
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What Is Hazardous Waste?
  Characteristic hazardous wastes ("D" wastes)
   - Ignitable (i.e., burns readily): D001
   - Corrosive: D002
   - Reactive (e.g., explosive): D003
   - Toxic (D004 to 43)
  Listed hazardous wastes appear on one of four
  lists (currently, more than 400 wastes)
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What Is Hazardous Waste?
  Listed sources ("F" and "K" wastes)
  Listed chemicals ("P" and "U" wastes)
  Note: many exemptions
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What Is Hazardous Waste?
  A simple way to remember waste codes
  FKD UP
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Typical  Hospital Hazardous Waste
  Mercury and mercury-containing items
  Includes whole items and spill residues
  Photographic/X-Ray fixer solutions
  Silver recovered from fixer, if not recycled
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Typical Hospital Hazardous Waste
  X-Ray Film containing silver or other metals
  Ethanol and formaldehyde/ethanol solutions
  Spent, off-spec, or excess laboratory
  chemicals (solvents, acids, bases, etc.)
  Chemotherapy drugs
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Typical Hospital Hazardous Waste
(Continued)
  Waste, excess, and off-spec paints and
  cleaning products
  Fluorescent light bulbs, if not managed as
  Universal Wastes
  Other types include high-intensity discharge
  (HID), neon, mercury vapor, high pressure
  sodium, and metal halide lamps
  Batteries, if not managed as Universal Wastes
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Typical Hospital Hazardous Waste
(Continued)
  Computers/monitors, circuit boards, and other
  lead-bearing electronics
  Includes all cathode ray tube (CRT) screens
  Compressed gases (generally, any that are
  ignitable)
  Waste pesticides, fungicides, etc.
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Specific Hospital Hazardous
Wastes
                 Cerrobend
  X-ray shielding putty used to protect patients
  from damage to adjacent healthy tissue during
  irradiation of tumors and other confined areas
  Contains Lead and Cadmium
  Discarded material and shavings can be
  characteristic toxic HW when disposed
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Specific Hospital Hazardous
Wastes (Continued)
           Chemotherapy Drugs
  Several chemotherapy drugs (antineoplastics)
  are listed in 40 CFR 261.33(f) (U-listed HW)
  Listing includes: discarded commercial
  chemical products, off-specification species,
  container residues, and spill residues
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Specific Hospital Hazardous
Wastes (Continued)
  Some Examples:
   - chlorambucil (U035)
   - cyclophosphamide (U058)
   - daunomycin (U059)
   - melphalan (U150)
   - mitomycin C (U010)
   - streptozotocin (U206)
   - uracil mustard (U237)
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Specific Hospital Hazardous
Wastes (Continued)
        Mercury Containing Devices & Products
                In Patient Rooms
  Temperature Measurement
  Blood Pressure
  Nursing Incubators
  Room Temperature Controllers
  Batteries
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Specific Hospital Hazardous
Wastes (Continued)
        Mercury Containing Devices & Products
          In Storage & Maintenance Rooms
  Antifouling agents
  Cleaning Chemicals
  Degreasers
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Specific Hospital Hazardous
Wastes (Continued)
        Mercury Containing Devices & Products
          In Storage & Maintenance Rooms
  Preservatives
  Solvents
  Outdated mercury-containing equipment
  Paints
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Specific Hospital Hazardous
Wastes (Continued)
        Mercury Containing Devices & Products
           In Treatment & Surgery Rooms
  Merthiolate
  Mercury Nitrate
  Mercury Iodide
  Mercurochrome
  Thimerosal
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Specific Hospital Hazardous
Wastes (Continued)
        Mercury Containing Devices & Products
           In Treatment & Surgery Rooms
  Esophageal Dilators
  Cantor Tubes
  Miller Abbot Tubes
  Feeding Tubes
  Dental Amalgam
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Specific Hospital Hazardous
Wastes (Continued)
            Sodium Azide-P105

  Also found in Enterococcus agars
  Listed in 40 CFR 261.33(e) (P-listed HW)
  Listing includes: discarded commercial
  chemical products, off-specification species,
  container residues, and spill residues
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    Typical Laboratory Hazardous
    Wastes
Which are
hazardous?
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Requirements for CE-small
Quantity Generators
  You are considered a CE-SQG if you generate
  no more than 220 Ibs (100 kg) of hazardous
  waste and no more than 2.2 Ibs (1 kg) of
  acutely hazardous waste in a calendar month.
  You are exempt from hazardous waste
  management regulations provided that you
  comply with the basic requirements.
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Requirements for CE-small
Quantity Generators
  NOTE: Your building/clinic may be part of a larger
  facility and subject to regulations based on total
  hazardous waste generation.
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Requirements for CE-SQG
Basic Requirements
  Identify your hazardous waste
  Comply with storage quantity limits
  No more than 220-lbs (100-kg)
  Ensure proper treatment and disposal of your
  waste
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Requirements for CE-SQG
Basic Requirements (Continued)
  Ensure proper treatment and disposal of your
  waste
  Good housekeeping
  Minor mercury or lab chemical spills cleaned
  immediately
  Containers with volatile wastes kept closed
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Requirements for CE-SQG
Basic Requirements (Continued)
  Deliver your hazardous waste to:
   - A state or federally regulated hazardous waste
    management treatment, storage, or disposal facility
   - A facility permitted, licensed, or registered by a state
    to manage municipal or industrial solid waste
    (potential liabilities)
   - A facility that uses, reuses, or legitimately recycles
    the waste (or treats the waste prior to use, reuse, or
    recycling)
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Requirements for CE-SQG
Otherwise the facility is fully subject to
regulation as a SQG
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Disposal Down the Drain
  Beware of septic system hook-ups and floor drains.
  Any hazardous waste disposed down the drain could
  be both a RCRA and SDWA (UIC) violation.
  Do not dispose of chemicals in sinks without prior
  approval from your publicly owned treatment works
  (POTW).
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Disposal Down the Drain
  Be wary of RCRA hazardous wastes that may not
  reach treatment plants (e.g., volatilization or pipe
  leaks).
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Satellite Accumulation
  Only permitted at or near point of generation
  Label container with:
  - "Hazardous Waste"
  - Contents
  Keep containers sealed
  Keep in good condition
  Store no more than 3 days in excess of 55 gal
  or 1 qt for acutely hazardous waste
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Requirements for
Small Quantity Generators
  If your facility generates between 220 Ibs (100
  kg) and 2,200 Ibs (1,000 kg) of hazardous
  waste and no more than 2.2 Ibs (1 kg) of
  acutely  hazardous waste in a calendar month,
  you are a SQG.
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Requirements for SQGs
  Obtain and use an EPA Identification Number
  Correctly manage hazardous waste on site
  Correctly manifest and ship waste off site
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Requirements for SQGs:
Obtaining an EPA ID Number
  EPA and states use these 12-character numbers
  to monitor and track waste activities
  You will need the number when you send waste
  off site to be managed
  EPA ID numbers can be obtained from EPA
  Region 2 offices: call (212) 637-4106
  NJ also requires numbers for certain CE-SQGs
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Requirements for SQGs:
Correctly Manage HW on Site
  Meet hazardous waste accumulation and
  storage requirements
  Ensure that hazardous waste meets the Land
  Disposal Restrictions (LDR)
  Minimize risks from fires, spills, and other
  releases
  Be prepared for emergencies
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Requirements for SQGs:
Correctly Manage HW on Site
  Label each container with:

  - "Hazardous Waste"
  - Specific description of contents
  - Date the waste was generated (also see
    satellite accumulation.)
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Requirements for SQGs:
Correctly Manage HW on Site
  Keep containers sealed, except when adding
  or removing waste, and secured from failure
  Weekly inspections with log book entries
  Maintain in good condition
  Store waste no more than 180 days (270
  days if TSDF is more than 200 miles away)
  Accumulate no more than 13,228-lbs (6,000-
  kg)
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Requirements for SQGs:
Correctly Manage HW on Site
  Ensure that hazardous waste meets the Land
  Disposal Restrictions (LDR) requirements
  Normally treated by the designated Treatment,
  Storage, & Disposal Facility (TSDF)
  Send the receiving TSDF a completed LDR
  form
  Meet the LDR requirements if treating on site
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Requirements for SQGs:
Correctly Manage HW on Site
  Minimize risks from fires, spills, and other
  releases
  Ensure that all employees are thoroughly
  familiar with proper waste handling and
  emergency procedures
  Internal communications or alarm system
  Voice is OK for small facilities
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Requirements for SQGs:
Correctly Manage HW on Site
  Telephone at the site for calling emergency
  assistance
  Have available and maintain:
  - Fire extinguishers
  - Spill control material
  - Decontamination supplies
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Requirements for SQGs:
Correctly Manage HW on Site
  Adequate water for fire fighting
  Sufficient aisle space for emergencies
  Advance emergency arrangements with:
   - Fire department
   - Police department
   - Emergency response teams
   - Equipment suppliers & emergency contractors (often
    handled by transporter/TSDF)
   - Hospitals
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Requirements for SQGs:
Correctly Manage HW on Site
  Be prepared for emergencies
  Designate an Emergency Coordinator
  Must be on call or on the premises at all times
  to coordinate all emergency response
  measures
  Post emergency information next to the phone
  Name, office and home phone numbers, and
  address of the emergency coordinator
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Requirements for SQGs:
Correctly Manage HW on Site
  Location of emergency equipment
  Fire extinguishers
  Fire alarms
  Spill control materials
  Phone numbers of the fire department
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Requirements for SQGs:
Correctly Manifest and Ship Waste
  Select a TSDF and transporter
  Ensure that they have necessary permits
  Ensure that hazardous waste shipments are
  properly packaged, labeled, marked, and
  placarded to DOT regulations (usually done by
  transporter)
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Requirements for SQGs:
Correctly Manifest and Ship Waste
  Prepare hazardous waste manifest correctly
  Keep all copies for at least 3 years
  Track signed TSDF copies
  Send copies where required on form
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Summary of Additional Requirements
for LQG (Beyond SQG Requirements)
    If you are a Large Quantity Generator (LQG),
    i.e., generating more than 2,200 Ibs (1,000 kg)
    of hazardous waste or more than 2.2 Ibs (1 kg)
    of acutely hazardous waste in a calendar
    month, you must comply with the full set of
    hazardous waste regulations.
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Summary of Additional
Requirements for LQG (Cont.)
  May accumulate any amount of hazardous waste for
  90 days or less, without a permit, provided that you:
  Meet the technical standards for the storage unit.
  Accumulate hazardous waste under the satellite
  accumulation requirements without a permit.
  Prepare a written contingency plan.
  Train employees on hazardous waste management
  and emergency response:
  Meet documentation requirements.
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Summary of Additional
Requirements for LQG (Cont.)
  Submit a Biennial Report to your EPA
  Regional Office (annual in  NY State). Reports
  submitted for off-site shipping must include:
  - Your EPA identification number;
  - Transporter and permitted TSD facility information;
  - Description and quantity of waste;
  - Actions taken to reduce the  volume and toxicity of
    the waste, and the results of those actions.
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Summary of Requirements for
Treatment, Storage, And/or
Disposal  Facilities (TSDF)
  Treatment: Any method, technique, or process designed to
  change the physical, chemical, or biological character or
  composition of any hazardous waste.
  Storage: Holding hazardous waste for a temporary period, at the
  end of which the hazardous waste is treated, disposed,  or stored
  elsewhere.
  Disposal: The discharge, deposit, injection, dumping, spilling,
  leaking, or placing of any solid or hazardous waste on or in the
  land or water. A disposal facility is any site where hazardous
  waste is intentionally placed and at which the waste will remain
  after closure.
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Summary of Requirements for
TSDFs
  Must have a permit from EPA or an
  authorized state
  Must have technical capability and
  capacity to handle the waste
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Summary of Requirements for
TSDFs
  Must meet financial requirements (e.g.,
  insurance)
  Must have a closure plan
  Must meet more stringent operating and
  training requirements
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Finding Compliance Information
  To find out what listings EPA has for your
  facility, or to look up your TSD:
  Envirofacts: http://www.epa.gov/enviro/
  Enforcement & Compliance History Online:
  http://www.epa.gov/echo/
  To find P2 ideas and other references:
  http://www.epa.gov/Region2/p2/health.htm
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Universal Waste
  Final Rule published in May 1995
  Details are located at 40 CFR Part 273
  The rule is optional for states because it is less
  stringent than existing regulations, but is in
  effect in all of Region 2 (NJ, NY, PR & VI)
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Universal Waste
  Before shipping across state lines, note:
  Universal Waste Rule may be used only if
  adopted by receiving state
  Hazardous waste requirements apply if not
  adopted in receiving state
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Universal Waste (Cont.)
  Defines streamlined management regulations
  for "widely generated wastes"
  Hazardous waste batteries
  Hazardous waste pesticides that are recalled
  or sent to a collection program
  Mercury-containing thermostats
  Spent fluorescent lamps and other hazardous
  lamps (with mercury, and some lead)
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Universal Waste (Cont.)
  Lessens regulatory burden on collection
  programs
  Eliminates concern for retailers that
  wastes may have been generated by
  RCRA-regulated generator
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Universal Waste (Cont.)
  Ensures that waste goes to proper
  treatment, recycling, or disposal facility
  Has labeling and storage requirements,
  but less stringent than for hazardous
  waste
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Universal Waste (Cont.)
  Small Quantity Handler of Universal Waste
  - Accumulates less than 5,000kg (2,270 Ib)

  Large Quantity Handler of Universal Waste
  - Accumulates 5,000kg or more (2,270 Ib)
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Universal Waste (Cont.)
  Notify EPA, if no hazardous waste ID already
  obtained
  Universal Waste Transporter
  Must meet DOT requirements
  Destination Facility
  Must meet all requirements that would
  otherwise apply
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RCRA Inspection Authority
42 USC Section  6927 (SWDA 3007
  "(a) Access entry: ...any person who generates,
  stores, treats, transports, disposes of, or otherwise
  handles or has handled hazardous wastes shall, upon
  request of any officer, employee or representative of
  the Environmental Protection Agency...or...of a State
  having an authorized hazardous waste program,
  furnish information relating to such wastes and permit
  such person at all reasonable times to have access to,
  and to copy all records relating to such wastes."
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RCRA Inspection Authority
42 USC Sec. 6927 (SWDA 3007)
(Continued)
  "...such officers, employees or representatives are
  authorized -
  (1) to enter at reasonable times any establishment or
  other place where hazardous wastes are or have been
  generated, stored, treated, disposed of, or transported
  from;
  (2) to inspect and obtain samples from any person of
  any such wastes and samples of any containers or
  labeling for such wastes."
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RCRA Inspection Basics
  RCRA inspections are unannounced in nearly
  all cases
  Team may include one or two inspectors...or
  may be as big as 4-6 for a large facility (or
  more for a "multi-media inspection.")
  "Credentials" will be presented by the inspector
  upon entry/introduction. (Note that they must
  remain in the inspector's possession and may
  not be photocopied.)
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RCRA Inspection Basics
(Continued)
  Inbriefing - introductions, explanation of procedures,
  schedule for the day(s).
  Review of storage areas, satellite accumulation areas,
  waste-generating activities, loading docks, dumpsters,
  material/product storage, etc.
  Will include the areas that you consider HW areas and
  others you may not think of as such.
  Review of paperwork (manifests, waste ID, training
  records, MSDS forms, etc.).
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RCRA Inspection Basics
(Continued)
  Outbriefing - preliminary findings, planned
  follow-up.
  Follow-up through phone calls or "information
  request letters" is common.
  Feel free to ask questions throughout the
  process.
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RCRA Enforcement
(If There Are Violations...)
    **
Enforcement decisions are not made on-site.
Enforcement, if necessary, may include:
    NOV - w/o penalty (may precede one of
  the following and/or may accompany an
  information request letter).
    Administrative Complaint (Admin. Order)
  w/penalty.
    **
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RCRA Enforcement
(If There Are Violations...)
  Enforcement, if necessary, may include:
  - Civil Judicial Referral to DOJ.
  - 7003 Order for imminent/substantial
    endangerment.
  - Referral to another EPA/state program
  - Criminal referral.
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Closing Comments
  Most small to mid-sized hospitals should be
  operating as at least SQGs. However, the
  proper category can only be confirmed through
  a full chemical and waste inventory from cradle
  to grave.
  Waste identification is important for all areas of
  the hospital — train all technicians in waste
  determination and satellite storage.
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Closing Comments
  Use the Universal Waste Rule, where
  applicable.
  Check web pages and ask questions of
  regulatory agencies, trade groups, and
  professional societies.
  Always anticipate inspections - perform
  self-audits,  and keep records.
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Hazardous Waste Contacts
(EPA Region2)
  For more information about hazardous waste
  requirements for hospitals and healthcare:
  EPA Region 2 RCRA Compliance Branch
  - Steven Petrucelli, (212) 637-3129
  - General number, (212) 637-4145
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Hazardous Waste Contacts
(EPA Region2)
  EPA Region 2 Compliance Assistance
  Program
  - Diane Buxbaum, (212) 637-3919
  EPA Region 2 Solid Waste Program
  - Lorraine Graves, (212) 637-4099
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Hazardous Waste Contacts
(EPA National & States)
  EPA RCRA Hotline (800) 424-9346
  New York State DEC Hazardous Waste
  Generator Hotline (800) 462-6553
  New Jersey State DEP Bureau of Solid and
  Hazardous Waste Enforcement (609) 584-
  4250
  Caribbean Environmental Protection Division
  (787) 729-6951
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RCRA Inspections and
Enforcement by EPA Region  2
  To date, EPA Region 2 has:
   -  Inspected at least 12 hospitals in the past 3 years
   -  Initiated 4 enforcement actions against hospitals
   -  Assessed $620,818 for penalties for violations by hospitals,
     ranging from $57,749 $279,900
  The number of inspections and enforcement actions
  at hospitals is expected to increase.
  We conduct inspections throughout the Region (NJ,
  NY, PR, and VI), from the heart of big cities to the
  smallest of towns.
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Common Violations  Found  at
Hospitals
  Failure to perform waste identification -- frequently
  observed examples are cited on the next few slides

  Failure to determine or meet relevant requirements
  for the proper generator category, often resulting
  from inadequate waste ID
   - If your facility generates any acutely hazardous waste (P-
     waste), it is likely to be a LOG; examples include sodium
     azide, nicotine, or arsenic trioxide (Trisonex)
   - According to the regulations, you are exempt from needing
     a TSD permit only if you comply with the appropriate
     generator requirements
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Common Violations  Found at
Hospitals (continued)
  Failure to treat or dispose of waste as hazardous
  Inadequate or improper labeling, waste tracking, or
  container management
  Failure to regularly inspect hazardous waste storage
  areas
  Inadequate training of staff responsible for
  hazardous waste management
  Failure to minimize releases
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Typical Hospital Hazardous Waste
  Mercury
  Chemotherapy drugs
  Lead shielding
  Photo/X-Ray Fixer or
  X-Ray film (silver)
  Formaldehyde/ethanol
  solutions
  Lab chemicals
  (solvents, acids, etc.)
Compressed gases
Spent lamps
Batteries
Paints
Pesticides, fungicides,
etc.
Computers and
electronics
CRT screens
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Finding Compliance Information
  To find out what listings EPA has for your
  facility, or to look up your TSD:
  Envirofacts:  http://www.epa.gov/enviro/
  Enforcement & Compliance History Online:
  http://www.epa.gov/echo/
  To find P2 ideas and other references:
  http://www.epa.gov/Region2/p2/health.htm
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RCRA Inspection Authority
42 USC Section 6927 (SWDA 3007
  "(a) Access entry:  ...any person who generates,
  stores, treats, transports, disposes of, or otherwise
  handles or has handled hazardous wastes shall,
  upon request of any officer, employee or
  representative of the Environmental Protection
  Agency...or...of a State having an authorized
  hazardous waste program, furnish information
  relating to such wastes and permit such person at all
  reasonable times to have access to, and to copy all
  records relating to such wastes."
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RCRA Inspection Authority (cont.)
42 USC Sec. 6927 (SWDA 3007)
  "...such officers, employees or representatives are
  authorized -
  (1) to enter at reasonable times any establishment or
  other place where hazardous wastes are or have
  been generated, stored, treated, disposed of, or
  transported from;
  (2) to inspect and obtain samples from any person of
  any such wastes and samples of any containers or
  labeling for such wastes."
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RCRA Inspection Basics
  RCRA inspections are unannounced in
  nearly all cases
  Team may include one or two inspectors...or
  may be as big as 4-6 for a large facility (or
  more for a "multi-media inspection.")
  "Credentials" will be presented by the
  inspector upon entry/introduction. (Note that
  they must remain in the inspector's
  possession and may not be photocopied.)
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RCRA Inspection Basics
(Continued)
  Review of storage areas, satellite accumulation
  areas, waste-generating activities, loading docks,
  dumpsters, material/product storage, etc.
  Will include the areas that you consider HW areas
  and others you may not think of as such.
  Review of paperwork (manifests, waste ID, training
  records, MSDS forms, etc.)
  Close-out briefing
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RCRA Enforcement
(If There Are Violations...)
  Enforcement decisions are not made on-site
  Follow-up request for information, as
  provided for under RCRA 3007, is common
  Enforcement, if necessary, may include:
  - ** NOV - w/o penalty (may precede one of
    the following and/or may accompany an
    information request letter).
  - ** Administrative Complaint (Admin.
    Order) - w/penalty (up to $32,500/day.)
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RCRA Enforcement
(If There Are Violations...)
  Enforcement, if necessary, may include:
  - Civil Judicial Referral to DOJ.
  - 7003 Order for imminent/substantial
    endangerment.
  - Referral to another EPA/state program
  - Criminal referral.
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Closing Comments
  Hazardous waste can be, and is likely to be,
  generated throughout the hospital in both expected
  and unexpected areas.
  Waste identification and knowledge of hazardous
  waste requirements is important in all areas of the
  hospital.
   - Train all technicians in waste determination/management
   - Explain waste management procedures to all personnel
     who may generate hazardous waste
   - Ensure that all technicians and generators know who to call
     for assistance and further information.
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Closing Comments (continued)
  Document waste determinations, related
  discussions, and procedures;  it will expedite
  inspections and help in training new staff and
  failure to document the waste determination
  may be a violation of RCRA.
  Check web pages and ask questions of
  regulatory agencies, trade groups,  and
  professional societies.
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Closing Comments (continued)
  Hospitals are responsible not only for the actions
  performed by their staff, but may also be responsible
  for those of their contractors/consultants, whether
  they are full-time on-site contractors, managing
  wastes as part of equipment maintenance contracts,
  or specifically  hired for waste management activities.
  Always anticipate an inspection by regulators --
  perform self-audits, keep records organized and
  accessible, and ensure that good operating
  procedures are not just implemented, but also
  maintained.
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Regulation of Chemo Wastes
        Under RCRA
          John Gorman
          EPA Region 2
          212-637-4008
       gorman.john@epa.gov
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RCRA Regulated  Chemotherapy Wastes

       •  Eight are U-listed:
          - Chlorambucil (Leukeran) (U035)
          - Cyclophosphamide (Cytoxan, CTX, Neosar, Procytox)
            (U058)
          - Daunomycin (Daunorubicin, Cerubidine, DaunoXome,
            Rubidomycin, Liposomal Daunorubicin) (U059)
          - Diethylstilbestrol (Diethylstilbesterol, DBS,  Stilbestrol,
            Honvol, Stilbesterol) (U089)
          - Melphalan(Alkeran,L-PAM)(U150)
          - Mitomycin C (Mitomycin, Mutamycin) (U010)
          - Streptozotocin (Streptozocin, Zanosar) (U206)
          - Uracil Mustard (U23 7)
                          EPA Region 2
                    Healthcare Compliance Initiative
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RCRA Regulated Chemotherapy Wastes

      •  One is P-listed:
        -  Arsenic Trioxide (Trisenox) (P012)
                      EPA Region 2
                  Healthcare Compliance Initiative
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Chemotherapy Wastes (Cont'd)

      • Other listed chemicals used in cancer research or
        treatment; but not FDA approved:
         - Azaserine (UO15)
         - Chlornaphazin (U026)
         - Ethyl Carbamate (U238)
         - 3 -MethyIcholanthrene (U15 7)
                       EPA Region 2
                   Healthcare Compliance Initiative
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     Bulk & Trace Chemo
These terms do not exist in the federal
regulatory program
Mixture rule applies to listed chemo
wastes (see 40 CFR §261.3(a)(2)(iv))
No minimum quantity or concentration to
exit regulatory system
                EPA Region 2
            Healthcare Compliance Initiative
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           Mixture Rule
A solid waste is a hazardous waste if:
It is a mixture of a solid waste and a
hazardous waste not listed solely because
it exhibits a characteristic
                 EPA Region 2
             Healthcare Compliance Initiative
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 Practical Application to PPE

HW only if contaminated with listed chemo
wastes
Solid waste if uncontaminated
Signs of contamination include: shiny
sheen, change in color, change in texture
or feel of the PPE, or seeing the material
on the PPE
Note:  NIOSH & OSHA recommend
handling all PPE as contaminated
               EPA Region 2
            Healthcare Compliance Initiative
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Management of Containers

Containers may also be regulated
 - If the container is not "empty" and
 - if they formerly held a hazardous waste
Different rules for P-listed and U-listed
wastes
                EPA Region 2
            Healthcare Compliance Initiative
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  Empty Containers - U-Listed

    Wastes (40 CFR §261.7)

Containers, IV bags, vials and inner liners
that have held U-listed hazardous waste are
deemed empty when:
 • All the wastes have been removed that can be
  removed,
 • No more than one inch of residue remains on the
  bottom of the container or inner liner, or
 • No more than 3 percent by weight of the total
  capacity of the container remains in the container
  or inner liner if the container is less than or equal
  to 110 gallons in size.
Any residues removed from the container are
managed as listed HW.
                 EPA Region 2
             Healthcare Compliance Initiative
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      P-Listed Wastes
Not subject to the empty container rule
Containers, IV bags, vials and inner
liners that have held P-listed hazardous
waste are a HW unless triple rinsed
with an appropriate solvent
The rinse water must be managed as a
hazardous  waste.
               EPA Region 2
            Healthcare Compliance Initiative
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 Best Management Practices
Handle all chemo wastes as HW
Reverse distribution
Pharmacy as accumulation area
Special marking on regulated chemo
containers
Develop standard policy for PPE
               EPA Region 2
           Healthcare Compliance Initiative
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                    r
r
                      r
U.S. Environmental Protection Agency
        Emergency Manage
Oil Prograr

November 2004
    7^>X  *'£•
         f
-------
  r
Update Outlin
Introduction-What is SPCC?
Regulatory History
Implementation Issues
Next Steps
                                        Continues
-------
     Prev
Establishes procedures, methods, and equipment
requirements to help prevent oil spills that could
reach navigable waters.

Requires that facilities develop and implement Spill
Prevention, Control, and Countermeasure (SPCC)
Plans.
-------
  ope of the SP
Applies to non-transportation related facilities that:
 - Could reasonably be expected to discharge oil into
   navigable waters of the United States or adjoining
   shorelines, and
 - Have an aggregate aboveground storage capacity
   greater than 1,320 gallons (counting only containers
   with a capacity of 55 gallons or more), or
 - Have a total underground storage capacity greater
   than 42,000 gallons.
Excludes permanently closed containers and
completely buried storage tanks subject to all technical
requirements of 40  CFR Parts 280 and 281.
-------
             lion of the Rul
 ubpart A    All facilities and all types of oil

Subpart B    Petroleum oils and non-petroleum oils
Subpart C
Except those oils covered in Subpart C.

Animal fats and oils and greases, and fish
and marine mammal oils; and vegetable
oils from seeds, nuts, fruits, and kernels
Subpart D    Response requirements
-------
A\\
acilities, All Types
  Section 112.1
   - General applicability
  Section 112.2
   - Definitions
  Section 112.3
   - Requirement to prepare and implement Plans;
     including:
      * Compliance dates
      * Professional Engineer certification
      * Maintaining and making Plan available
        Extension of time
                                         Continues
-------
A\\
(continued)
  Section 112.4
   - Amendment of SPCC Plan by Regional Administrator
  Section 112.5
   - Amendment of SPCC Plan by owners or operators
  Section 112.7
   - Prepare Plans in writing and according to good
     engineering practices
   - Management approval
   - Alternative formats
-------
     eral Requirements
112.7, General requirements for SPCC Plans
      General facility description, including:
      •  Type of oil and storage capacity, physical layout, and
        diagram
      •  Discharge prevention measures
  )    •  Discharge and drainage controls
      •  Countermeasures for discharge discovery,response,
        and cleanup
      •  Methods of disposal of recovered materials
      •  Contact list and phone  numbers
.. ,    Description of potential discharges from equipment
 !'    failure
 )    Appropriate secondary containment
-------
     eral  Requirements
(continued)
112.7, General requirements for SPCC Plans (continued)
  )    Impracticability of secondary containment
' 0    Inspections, tests, and records
v.)     Personnel, training, and discharge prevention procedures
      Security measures
      Facility tank car and tank truck loading/unloading rack
      Evaluation of containers for brittle fracture or other
      catastrophe
      Conformance with applicable requirements and
      procedures
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      ific  Facility Requirements
Sections 112.8 and 112.12
 - Onshore Facilities (excluding production facilities)
    « Facility drainage-112.8(b) and 112.12(b)
    * Bulk storage containers-112.8(c) and 112.12(c)
    « Facility transfer operations-112.8(d) and 112.12(d)
Section 112.9
 - Oil Production Facilities (onshore)
Section 112.10
 - Oil Drilling and Workover Facilities (onshore)
Section 112.11
 - Oil Drilling,  Production, or Workover Facilities (offshore)
-------
-------
   ule Timeline
Initial Promulgation
Original requirements for SPCC Plan preparation,
implementation, and amendment.
Proposed Rule
Revise applicability and SPCC Plan procedures, and
add a facility notification provision.
Proposed Rule
Implement Oil Pollution Act of 1990-response plan
requirements and make minor technical changes.
Proposed Rule
Reduce the information collection burden.
                                           Continues
-------
   ule Timeline
(continued)
Final Rule: SPCC Rule Amendments
Incorporates many of the proposed modifications.
Final Rule: Compliance Date Extension
Additional time to prepare and update SPCC Plans.
Final Rule: Compliance Date Extension
Additional time to understand published clarifications.
NODAs
Certain Facilities and Oil-filled and Process Equipment
Guidance, Rulemaking, and Outreach
Address additional issues as appropriate.
-------
    land Oil
In 1988, an aboveground storage tank owned by the
Ashland Oil Company collapsed and spilled
approximately 3.8 million gallons of diesel fuel.
Approximately 750,000 gallons were released into
the Monongahela River.
EPA formed an SPCC Task Force to:
 - Focus on the prevention of large, catastrophic oil spills.
 - Make recommendations on the SPCC program.
-------
Photos courtesy of
NOAA Office of Response and Restoration, National Ocean Service
-------
002
 Revised rule incorporates suggestions of the SPCC
 Task Force following the Ashland Oil Spill.
 Is performance-based rather than prescriptive.
 Incorporates aspects of the 1991, 1993, and  1997
 proposals.
 Uses a new format and "Plain English" style.
-------
  erview of Rule  C
Provides regulatory relief:
 - Exempts completely buried tanks, small containers,
   and most wastewater treatment systems.
 - Raises the regulatory threshold.
 - Reduces information required after a discharge, and
   raises the regulatory trigger for submission.
 - Increases the frequency of Plan review from 3 to 5
   years.
 - Allows for alternative formats for SPCC Plans with
   cross-reference.
                                               Continues
-------
  erview of Rule Changes
                               ^^
(continued)
Clarifies applicability for the operational use of oil.
Makes the Professional Engineer certification more
specific.
Clarifies mandatory requirements.
Establishes brittle fracture evaluation.
Clarifies employee training requirements.
Allows flexibility in meeting many rule provisions by
providing equivalent environmental protection or
developing contingency plans.
-------
-------
ompliance Date Extensions
Compliance dates for the SPCC amendments were
extended in 2003 and 2004 (§§112.3(a) and (b)).
 -  Provides additional time for regulated community to
   update or prepare Plans, especially following the
   litigation settlement (2004 extension).
 -  Alleviates the need for individual extension requests.

The 2004 extension also amended the compliance
deadlines for onshore and offshore mobile facilities
-------
       ent  Compliance  Dates
 A facility
 starting operation...
 On or before 8/16/02
After 8/16/02 through
8/18/06
After 8/18/06
Must...
Maintain existing Plan
Amend Plan no later than 2/17/06
Implement Plan no later than 8/18/06
Prepare and implement a Plan no
later than 8/18/06
Prepare and implement a Plan before
beginning operations
Onshore and offshore mobile facilities must prepare, implement,
and maintain a Plan as required by the rule.
   - A facility must amend and implement the Plan, if necessary
     to ensure compliance with the rule, on or before 8/18/06.
-------
Lawsuits filed by American Petroleum Institute,
Petroleum Marketers Association of America, and
Marathon Oil.
Terms of partial settlement published in Federal
Register on Tuesday May 25, 2004 (69 FR 29728.)
Litigation Issues:
 - Loading racks
 - Impracticability
 - Produced water and
   wastewater treatment
  Integrity testing
- Security
- Facility
- Navigable waters
  (Not resolved through settlement)
-------
-------
      nsio
uring the extension...
 The regulated community
 will update/prepare Plans
 and have additional time to
 understand recent
 clarifications of the rule.
 EPA is developing guidance
 to address the performance-
 based nature of the rule.
 Facilities must maintain a
 Plan in accordance with the
 extension.
After the extension...
   Regional Guidance will be
   available to the public
   Facilities must have an
   SPCC Plan in compliance
   with revised rule provisions.
   EPA will address additional
   issues as needed.
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    ional Guidance
EPA acknowledges there are additional policy issues
that require clarification and is working to address
them.
Clarifications can often be addressed through
performance-based provisions of the rule.
Currently developing guidance to regional inspectors
on how to evaluate SPCC Plans when environmental
equivalence and impracticability are claimed.
-------
Environmental Equivalence (§112.7(a)(2))
 - Facilities may deviate from certain substantive
   requirements of the SPCC rule (except secondary
   containment) by implementing alternate measures that
   provide equivalent environmental protection.

Impracticability (§112.7(d))
 - In situations where secondary containment is not
   practicable, the SPCC Plan must explain the reason.
 - The owner/operator must prepare an oil spill
   contingency plan and a written commitment of
   manpower, equipment, and materials.
-------
       J
       J
 Document!
Document!
-------
Environmental
Equivalence
 - State reason for
   nonconformance in Plan
 - Describe in detail the
   alternative method and
   how you will achieve
   environmental
   equivalence.
Impracticability
 - Clearly explain why
   containment measures
   are impracticable.
 - Conduct integrity testing
 - Develop a contingency
   plan (40 CFR 109)
 - Provide written
   commitment of
   manpower, equipment,
   and materials.
-------
   ional Guidance
Examples of issues to address in guidance
- Loading rack
- Integrity Testing
- Security
- Piping
- Mobile/portable containers
-------
    ma
Background and History of SPCC
Overview of the SPCC provisions
Extension
Regional Guidance and performance-based
provisions of the rule
-------
     More In
 hristopher Jimenez
Region 2 SPCC Coordinator
(732) 906-6847
  EPA Oil Program Website
  www.epa.gov/oilspill
  RCRA and EPCRA Call Center
  1-800-424-9346
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U.S. EPA's Audit Policy
-------
Purpose
  To enhance protection of human health and
  the environment by encouraging regulated
  entities to voluntarily discover, disclose, correct
  and prevent violations of federal environmental
  requirements.

  As incentive, EPA will forgo all gravity-based
  (non-economic benefit) penalties when the
  regulated entity satisfies all policy conditions.
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Conditions
  The violation was identified voluntarily
  The violation was discovered through:
  - an environmental audit; or
  - an environmental management system
      http://www.epa.gov/region02/ems
  (75% reduction possible otherwise)
-------
Conditions
  Promptly disclose violations in writing to EPA
  (within 21 days of discovery)

  In Region 2, send to:
     Regional Administrator, EPA Region 2
     c/o Compliance Assistance Section
     290 Broadway
     New York,  New York 10007-1866
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Conditions
  Must promptly correct violations (usually within
  60 days)

  Correcting the violation includes remediating
  any environmental harm associated with the
  violation, as well as implementing steps to
  prevent a recurrence of the violation.
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The Policy Excludes:
  Violations that result in serious actual harm or
  present an imminent hazard to public health,
  safety, or the environment


  Violations of any judicial/administrative orders
  or consent agreements


  Repeat violations (within three years)
-------
The Policy Excludes:
  Violations that are part of a pattern of similar
  violations across a multi-facility organization
  within the past five years.

  Criminal violations of individuals  (entities
  generally exempt)
-------
Audit Policy Disclosures from
Academic Institutions
  48 colleges and universities applied for
  amnesty so far.

  Although 10 of these disclosures are still under
  review,  a total of approximately 2.4 million
  dollars in penalties have been waived to date.
  No economic benefit was assessed.
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Audit Agreements
  Audit agreements allow EPA and the company
  to reach mutually acceptable terms regarding
  schedules for conducting the audit, and
  disclosing and correcting any violations
  discovered.

  Model Audit Agreement for Hospitals
  http://www.epa.gov/region02/healthcare
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Steps to Negotiate an Audit
Agreement
  Contact EPA for current model agreement.
  Submit commitment letter.
  EPA responds with "low inspection priority"
  letter.
  Submit draft agreement.
  EPA discusses comments, if any, with facility
  Draft agreement developed for final review.
  Final agreement signed.
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Why Bother Self-Reporting? - A
Cost/Benefit Analysis
  Increased attention from
  Government if self-report
  Potential for economic
  benefit penalties
We know you are there.
More likely to get
attention if don't report.

Penalty much lower than
would be assessed
through enforcement.
Limits circumstances
under which EPA will
prosecute criminally.
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Why Bother Self-Reporting? - A
Cost/Benefit Analysis
  Audit costs money
Cost of conducting audit
is much less than cost of
paying penalties.

May lose federal grants,
contracts, and other
funds if enforcement
occurs.
                         Bad publicity affects
                         fundraising.
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Why Bother Self-Reporting? - A
Cost/Benefit Analysis
  Must fix violations on a
  monitored schedule

  Must request and
  receive approval for
  extensions

  Must implement
  measures to prevent
  recurrence
Periodic auditing can
identify and correct
problems before they
become serious

Auditing can identify
wasted resources

Get a good night's sleep
knowing that things are
working as desired
-------
Advantages of Audit Agreements
  "Low inspection priority" designation
  More time to disclose and correct violations
  Other flexibility can be built into agreement to
  meet needs
  Single point of contact for all environmental
  regulatory issues
  Partnering with EPA can result in good
  publicity
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Resources
  John Gorman
  EPA Region 2 Audit Policy Coordinator
  212-637-4008 or gorman.iohn@epa.gov
  EPA Region 2's Auditing Website
  http://www.epa.gov/region02/capp/cip
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Common Violations - Hazardous
Waste
  Improper or lack of HW labeling
  No or improper weekly inspections of HW
  storage/satellite areas.
  Open containers of HW.
  Improper disposal of chemotherapy drugs
  Failure to perform or improper HW
  determinations.
  No or inadequate HW manifests.
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Common Violations - Hazardous
Waste
  Improper management of mercury-containing
  wastes, expired Pharmaceuticals, paints, etc.
  Lack of a contingency plan.
  Lack of or inadequate training of employees in
  HW management.
  Failure to upgrade/close USTs by 12/22/98.
  Malfunctioning leak detection systems.
  Improper consolidation of wastes from nearby
  facilities.
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Common Violations - Air
  Failure to use properly trained and accredited
  asbestos personnel.
  Failure to notify EPA of asbestos removal projects
  and to keep required documentation/records.
  Failure to properly dispose of asbestos debris.
  Failure to close parts washer lids when not in use.
  Failure to include spray paint booths and parts
  degreasers in air permit.
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Common Violations - Water
  No permit for noncompliance with wastewater
  discharges.
  No or inadequate secondary containment for
  storage tanks
  Improper disposal down floor drains.
  No Spill Prevention, Control and
  Countermeasure Plan.
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Common Violations - Lead Paint
  Failure to notify residents of lead paint in
  building or lack of knowledge of any lead
  hazard.

  Failure to provide EPA's pamphlet, "Protect
  Your Family from Lead in Your Home."
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Universa
-------
Overview
3€ Characteristics of Universal Wastes
n Goals of Universal Waste Rule
  What is considered Universal Wastes?
  Who generates Universal Wastes?
& Transporter of Universal Waste
  Destination Facilities
  Universal Wastes and the States
  Special Issues
-------
Characteristics of UW
§€ Generated in a wide variety of settings
  other than industrial settings usually
  associated with hazardous wastes
  Generated by a vast community of various
  sizes which pose implementation
  difficulties
  May be present in volumes of non-
  hazardous waste
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Goals
  Final Rule published in May 1995
§€ Details located at 40 CFR Part 273
& Defines streamlined management
  regulations for "widely generated wastes"
£ Targeted Goals of Rule are:
   El Encourage environmentally sound collection and
    recycling or treatment of universal waste
   El Improve implementation of the hazardous waste system
   El Ease regulatory burden
   El Reduce the hazardous wastes going to municipal
    landfills or municipal combustors
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What are Considered
Universal Wastes?
  Universal waste categories must be
  hazardous waste before they can be
  designated as universal wastes
  Four types of Federal universal wastes:
   E Batteries (e.g., nickel cadmium)
   El Certain pesticides that are either recalled or
    collected in waste pesticides collection
    programs
   El Mercury-containing thermostats
   El Lamps (e.g., fluorescent bulbs)
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Batteries
  Device consisting of electrically connected
  electrochemical cells designed to receive,
  store, and deliver energy
§£ Unbroken batteries where the electrolyte
  has been removed
  Lead batteries - universal waste or Part
  266 Subpart G
  Waste determination made by generator
-------
Pesticides
3£Unused pesticides banned from use
3£Damaged by temperature extremes
  Recalled pesticides become a UW
  when:
  EDGenerator participates in recall
  E Generator decides to discard or burn for
   energy
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Thermostats
§€ Temperature control devices containing
  metallic mercury in an ampoule and
  ampoules that have been removed from
  these devices
§£ UWR does not cover mercury containing
  equipment such as gauges, manometers,
  relays, and circuit boards
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Hazardous Waste Lamps
  Lamps are defined as the bulb or tube
  portion of an electric lighting device
  Fluorescent, high intensity discharge,
  neon, mercury vapor, high pressure
  sodium, and metal halide
  Exhibit toxicity characteristics for mercury
  or lead
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Universal Waste Handlers
(SQHUW)
  Small Quantity Handlers of Universal
  Wastes - less than 5,000 kilograms (2,270
  Ib) of all universal waste categories
§€ Regs for SQHUW found in Part 273
  Subpart G
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Universal Wastes Handler
(LQHUW)
  Large Quantity Handlers of Universal
  Wastes - 5,000 or more kilograms of all
  universal waste categories
§€ Regs for LQHUW found in Part 273
  Subpart C
  Once a handler triggers the LQHUW
  status, they remain for the rest of the
  calendar year
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Benefits of Handling
Universal Wastes
  Lessens regulatory burden on collection
  programs
  Eliminates concern for retailers that
  wastes may have been generated by
  RCRA-regulated generator
  Ensures that waste goes to proper
  treatment, recycling, or disposal facility
  Has labeling and storage requirements,
  but less stringent than for hazardous
  waste
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Transporters
  Persons who move UW shipments from a
  handler to another handler, a destination
  facility, or a foreign destination
§€ UW transporter regulations apply for any
  amount of UW
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Transporters con't
§£ Seven UW Requirements
     ^Applicability (40 CFR 273.50) - to whom the
      regulations apply
     H Prohibitions (40 CFR 273.51) - prohibits
      disposing, diluting, or treating UW
     E Waste Management (40 CFR 273.52) -
      comply with DOT regulations if UW fall
      under DOT hazardous waste definition
     mAccumulation Time Limits (40 CFR 273.53)
      - UW can be stored for up to 10 days
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Transporters con't
     [x]Response to Release (40 CFR 273.54) -
       immediately contain UW releases and
       handle residues appropriately
     ^Off-Site Shipments (40 CFR 273.55) -
       prohibits transporting UW to any place
       other than a UW handler, destination
       facility, or foreign destination
     HExports (40 CFR 273.56) - follow rules for
       exporting hazardous wastes
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Destination Facilities
§€ Treats, disposes of, or recycles UW
§€Same general requirements as traditional
 hazardous waste TSDF
§£ Subject to permitting and unit specific
 requirements
-------
Universal Waste and the
£ The rule is optional for states because it is
  less stringent than existing regulations,
  but is in effect in all of Region 2 (NJ, NY,
  PR & VI)
  Before shipping across state  lines, note:
   E Universal Waste Rule may be used only if
    adopted by receiving state
   E Hazardous waste requirements apply if not
    adopted in receiving state
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 Special  Issues
  Mercury-Containing and Rechargeable
  Battery Management Act signed on May 13,
  1996 effective in all 50 States
  El Goals -1. Decrease mercury content in batteries
         2. Increase voluntary recycling of batteries
& Collection, storage, transportation of used
  rechargeable batteries, lead-acid batteries,
  banned mercury-containing batteries, used
  consumer products containing batteries that
  can't be removed
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Review
  Defines streamlined management
  regulations for "widely generated wastes"
  hazardous waste batteries
  hazardous waste pesticides that are
  recalled or sent to a collection program
  mercury-containing thermostats
  spent fluorescent lamps and other
  hazardous lamps (with mercury, and some
  lead)
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Review
  Lessens regulatory burden on collection
  programs
  Eliminates concern for retailers that
  wastes may have been generated by
  RCRA-regulated generator
  Ensures that waste goes to proper
  treatment, recycling, or disposal facility
  Has labeling and storage requirements,
  but less stringent than for hazardous
  waste
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Review
  Small Quantity Handler of Universal Waste
  accumulates less than 5,000kg (2,270 Ib)
  Large Quantity Handler of Universal Waste
  accumulates less than 5,000kg (2,270 Ib)
  Notify EPA, if no haz. waste ID already
  obtained
  Universal Waste Transporter
  Must meet DOT requirements
  Destination  Facility - must meet all
  requirements that would otherwise apply
  Mercury-Containing & Rechargeable
  Battery Act
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    Compliance Assistance Program
    for Hospitals in Region 2

      The Region 2 Hospital Compliance
      Initiative Commenced on December
      27, 2002.
      480 hospitals in New York, New
      Jersey, Puerto Rico and the Virgins
      Islands were notified of the Initiative
      and invited to participate in the
      voluntary audit program.
 S*" M^
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The EPA/AHA 1998 Memorandum of
  Understanding

" Virtual Elimination of Mercury by 2005
• 33% Reduction of Solid Waste by 2005, 50%
  by 2010
• Identification and Elimination of PBTfs in the
  hospital environment
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Current Efforts
  •A New York Focus Group meeting since
  spring 2000 was set up to identify problems and
  needs
  •Two additional focus groups are planned:
  Please sign at the registration table if you wish
  to become a member of a New Jersey Hospital
  Focus Group or a Caribbean Hospital Focus
  Group
1 T ::.-1
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Seminars to provide compliance
information— as this one Information
about the Audit Policy Program
P2 and Voluntary Programs
Web site information
National H2E Partner and Award
Program
t,
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H2E Awards 2002 have given national
  recognition to 4 hospitals in New York
  and New Jersey

» Beth Israel Medical Center, Kings Highway
• St. John's Riverside Hospital 2 awards
• Hackensack University Medical Center
• University of Rochester, Strong Memorial Hospital 2
  awards (also one of 3 in the nation to earn the
  Environmental Leadership Award
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  Seminars/Conferences Past, Current,

  Future

• Region 1/2, Region 2/3, Caribbean and Greater New York
  Hospital Association 2001
• Hackensack University Medical Center 2002
• Long Island Jewish Medical Center 2003
  February 26, 2003 Beth Israel Medical Center, NYC--
  today.
  Planned sessions in NYC, in Albany with New York State
  Department of Environmental Conservation, Pollution
  Prevention Unit, in Rochester and in Princeton with New
  Jersey Hospital Association

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Action Plan
• Hospital Compliance Initiative
• Encourage hospitals to participate in the
  Voluntary Audit Program or, if the
  hospital is part of a hospital consortium,
  to pursue an Audit Agreement
• Provide technical assistance to hospitals
  upon request with audit information,
  relevant documents and web sites.
 t,
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VOLUNTARY ENVIRONMENTAL

PROGRAMS

Energy Star Buildings Partnership


  The ENERGY STAR BuildingsSM Partnership is a comprehensive
  energy-efficiency program for commercial and industrial buildings.
  The Partnership focuses on reducing waste and improving building
  performance by using high-efficiency energy technologies
  More than 7000 organizations are participating in the ENERGYSTAR
  Buildings and Green Lights® Partnership
  By 1999, cumulatively, these organizations had prevented 50.6 billion
  pounds of carbon dioxide (CO2) from being released into the
  atmosphere as a result of their energy-efficiency upgrades, which was
  equivalent to removing the pollution from 1.9 million cars, or planting
  2.6 million acres of trees annually
  Annual savings in 1999 was $1.6 billion, Today it is 5.
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     EnergyStar continued
      The EnergyStar general program is on the EnergyStar
      web site: http://www.energystar.gov/

      Hospitals can n Join the Partnership". Case studies are
      available by clicking on Success Stories under
      Participants
      http://yosemitel.epa.gov/Estar/business.nsf/webmenus/
      Healthcare

      There are currently more than 900 health-care/hospital
      facilities participating in EnergyStar
1  "T "::J
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National Performance Track
  National program designed to motivate and reward top
  environmental performance, through:
  National recognition as an environmental leader
  Access to ??State-of-the-Artn information
  Best practices database
  Peer exchange networking opportunities
  Informational briefings with senior EPA officials
  Streamlined environmental monitoring and reporting
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Performance Track continued

• Eligibility Criteria:
   • Mature Environmental Management System
   • Demonstrate achievements, commit to continued
    environmental improvements
   • Have a record of sustained compliance with
    environmental requirements
   • Commit to public outreach and performance
    reporting
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Benefits to the Environment from Performance Track:
    Reducing solid waste by 225 million pounds
    Reducing water use by 1.6 billion gallons
    Preserving/restoring 4,600 acres

Benefits to You:
    Public recognition (press releases, awards)
    Participation in events, peer exchanges
    Interaction with senior EPA officials
    Low priority for routine inspections
    Use of Performance Track logo
    Listing on EPA web sites, articles, case studies
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Performance Track is now accepting
applications for the program.
Marcia Seidner, EPA Region 2 Performance
Track Coordinator, 212-637-3584,
seidner.marcia@epa.gov
Performance Track Information Center
888-330-PTRK
http://www.epa.gov/performancetrack
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WasteWise

• Targets the reduction of municipal solid waste; waste
  that would otherwise end up in a trash dumpster.
  Currently 57 health care facilities are on the
  WasteWise list of partners, including:
  New York: Canton-Potsdam Hospital, New York
  Presbyterian Hospital, Southside Hospital, St. Luke's
  Memorial Center, St. Peter's Health Care Service
• New Jersey: Christian Health Care Center, Passaic
  Beth Israel, Robert Wood Johnson University Hospital,
  St. Mary's Hospital
  Puerto Rico: Jostra-Bentley Hospital
• Web site for additional information
  http://www.epa.gov/epaoswer/non-hw/reduce/wstewise/
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      More Voluntary Environmental Programs

         The Water Alliances for Voluntary Efficiency program (WAVE)
         encourages commercial businesses and institutions to reduce water
         consumption while increasing efficiency, profitability, and
         competitiveness


         http://es.epa.gov/partners/wave/wave.html


         Environmentally Preferable Purchasing is a federal-wide program
         that encourages and assists Executive agencies in the purchasing of
         environmentally preferable products and services (open to
         participation from any interested party) Currently 13 non-
         government  healthcare institutions/projects are listed on this
         website with contract information shown


         http://www.epa.gov/opptintr/epp/,
         http://notes.erg.com/eppstand2.nsf/Pages/Search.html7Open
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          The Pesticide Environmental Stewardship Program is a voluntary
          program that forms partnerships with pesticide users to reduce the health
          and environmental risks associated with pesticide use and implement
          pollution prevention strategies


          http://www.epa.gov/oppbppdl/PESP/


          Useful Websites
          EPA P2 Website:


          Region 2 EPA College and University web site may have useful
          information because of the laboratory/ institution overlap -
          Region 2 EPA Health Care web site
          http://www.epa.gov/region02/p2/health.htmftProg
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Contacts  at Region 2 EPA
        Pollution Prevention, Hospital Compliance Assistance
        Diane D. Buxbaum, 212-637-3919, buxbaum.diane@epa.gov
        Federal Facilities, EMS's and SEP's
        Kathleen Malone, 212-637-4083, malone.kathleen@epa.gov
        Audit Policy and Self-Disclosure
        John Gorman, 212-637-4080, gorman.john@epa.gov
        Hospital Hazardous Waste (RCRA)
        Steven Petrucelli, 212-637-3129, petrucelli.steven@epa.gov
        National Performance Track
        Marcia Seidner, 212-637-3584, seidner.marcia@epa.gov
        WasteWise
        Lorraine Graves, 212-637-4099, graves.lorraine@epa.gov
        Small Business Assistance Program
        Ronald Lockwood, 212-637-3413, lockwood.ronald@epa.gov

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-------
Partners for the Environment
    ITALS
    for a
    EALTHY
   VIRQNMENT'
            Money tent All You're Saving
             CLIMATE
  &EPA
WVSTE
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What is WasteWise?

  • U.S. EPA voluntary
    partnership program

  • Started in 1994

  • Focuses on municipal solid
    waste
                             iWVSTE
                              rISE
                           Preserving Res
                                Wfaste
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What is WasteWise?
•
•
    Develop customized goals
     • 3 in waste prevention
     • 1 in recycling collection
     • 1 in buying or manufacturing
        products with recycled content
    Implement over a 3-year period
    Report progress annually

                                iWVSTE
                                  rISE
                               Preserving Res
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WasteWise Membership
Nearly 1,200 partners
representing 53 government and
business sectors
Who are the partners?
 • Numerous Fortune 500 companies
 • More than 20% are governments
 • 57 hospitals, pharmaceutical companies,
   and other medical service providers
More than 1 25 endorsers
representing 30
government and
business sectors
                                    ISE
                                Preserving Res
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WasteWise Accomplishments

  • Reduced more than 35 million
    tons of waste since 1994
  • Saved more than $1.1 billion
    since 1994
    Prevented the emission of
    25 million metric tons of
    carbon equivalent
    (MTCE) since 1994
                              ISE
                          Preserving Res
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WasteWise Accomplishments

    Challenges partners to reduce
    electronics, transport
    packaging, and C&D waste
    Promotes resource
    management strategy
    Assists partners in connecting
    waste reduction to climate
    impacts
    Recognizes partners
       • ^ _•    '       mm
    and endorsers annually   '\WASTE
                             "ISE
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Waste and Climate Chang

    Waste prevention and
    recycling activities:
     • Reduce emissions from extracting
       raw materials and manufacturing
     • Reduce carbon dioxide and
       methane emissions from waste
       combustion and landfills
       Increase carbon storage
       in forests
iWVSTE
  rISE
                               Preserving Res
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You  Make a Difference
  Action
             Payoff
m • T \ T .
suiiy
                 Equivalent to Removing
                    s From the Roa
                     One Yea
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                                ucrion
                    (WARM)
                                           jii wiiSt'i! Eiy 1l'
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                    »m!*»>on*
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Medical Services: Teaming  Up
with WasteWise
   Bert Fish Medical Center
   Bronson Methodist Hospital
   Dana Farber Cancer Institute
   Dartmouth Hitchcock Medical
   Center
   Fairview Health Services
   Fisher-Titus Medical Center
   Kaiser Permanente
   Marian Residence
   Memorial Hospital Association
Patrick B. Harris Psychiatric
Hospital
Redwood Area Hospital
St. Peter's Health Care
Services
Tulsa Regional Medical Center
University of Chicago Hospitals
University of Nebraska Medical
Center
...and many more!
                                           WASTE
                                              ISE
                                         Preserving Res
                                               Wfaste
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Medical  Services: Sample

WasteWise Results
•  Fisher-Titus Medical Center switched to soap in
   a soft plastic bag and lightweight box.
   Recycling the boxes and eliminating residue
   from the gravity dispense bags minimizes both
   packaging and product waste.
    •  Avoided waste disposal costs: $350
    •  Reduced annual purchasing expenses: $2,275
   Dartmouth-Hitchcock Medical Center switched
   from using a combination 32 oz. water pitcher
   with lid and 8 oz. plastic cup to a 16 oz. foam
   cup with lid for all patient use, minimizing
   waste.

    •  Reduced annual purchasing expenditures: $4,000
WASTE

  rISE
                                       Preserving Res
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Medical Services: Sample
Climate Achievement
  Dana Farber Cancer Institute
  recycled 86.77 tons of paper, the
  equivalent of taking approximately
  51 cars off the road for one year.

  By expanding their reusable tote
  system, Kaiser Permanente
  eliminated the use of approximately
  550,000 cardboard boxes, the
  equivalent of taking approximately
  124 cars off the road for one year.
iWVSTE
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WasteWise and Resource
Management
 WasteWise RM Resources:
 • RM Manual
   RM Web page
   
   Workshops and meetings
   Public recognition of RM achievements
   Technical assistance
                                1SE
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  Benefits of Joining WasteWise
Web Site and List Server
                       Partner Networking
    J   4 , J  • ^ •
     Helpline ana
 Account Representative
                       Satellite Forums
  Library of Technical
  Assistance Materials
                                             v=/EPA
      WasteWise Tip Sheet
      Waste Prevention

                                                       J
                                         •SEPA  Business Guide for
                                             Reducing Solid Waste
WasteWise
                                        EPA
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Partner Recognition
        Awards
Annual
Report
                          Bulletin
                         Update
                                   Banking, Financial
                                   and Insurance
                                   Industry
                               Rjrtnera mi tin-1 'iitliiar Edge of Snstainabifitj
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Joining WasteWise

    Enroll online at
    

    Receive technical assistance
    for RM

  • Use your H2E report for
    WasteWise reporting
                             iWVSTE
                               rISE
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WASTE
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-------