v>EPA
Unted Slates
Environmental Protector
Healthcare Environmental Assistance Resources
Pollution Prevention and Compliance Assistance
for Healthcare Facilities
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IDENTIFICATION AND
MANAGEMENT OF
REGULATED HAZARDOUS
WASTE
A Workshop Geared Towards
Healthcare Facilities
June 2006
EPA Region 2
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Please set all cell phones, pagers,
and PDAs to silent mode
EPA Region 2
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Agenda-1
Hazardous Waste & Healthcare
• Healthcare facilities manage many types of waste
- Normal solid waste (paper waste)
- Medical/infectious waste (red bag)
- Hazardous waste ,
- Radioactive Waste .
• These wastes are also regulated by state and local
regulations
EPA Region 2
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Agenda-2
Hazardous Waste & Healthcare (Cont'd)
• These wastes are regulated by many federal regulations,
such as I -j —-
- CAA -* —f~~ - CERCLA
- CWA (including oil pollution prevention and storm water)
- DBA I ^ . - FDA
-EPCRA - FIFRA
-NRC ' - OSHA
-RCRA - SDWA
-TSCA
• Today's presentation identifies federal hazardous waste
requirements under RCRA
EPA Region 2
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Agenda-3
Hazardous Waste & Healthcare (Cont'd)
• Healthcare issues covered today
- Lab/Storage clean-ups and impact on generator status
- Satellite accumulation areas
- Facility definition and transport between facilities
- Hospital-specific waste issues
i Chemotherapy agents
i Unused pharmaceuticals
i ER use (such as epinephrine and nicotine patches)
i Mercury laboratory wastes
i P- and U-type RCRA-listed wastes
I ETO explosion risk
I Picric acid
EPA Region 2
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Agenda-4
Course Overview
Exhibits
• Discarded Material - Exhibit I
• Solid Waste Exclusions - Exhibit II
• Hazardous Waste Exclusions - Exhibit III
--
• Listed Hazardous Waste - Exhibit TV
Delisted Wastes - Exhibit V
"Mixture" and "Derived - From" Rules - Exhibit VI
EPA Region 2
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Agenda-5
Course Overview (Cont'd)
Exhibits
• Hazardous Waste Characteristics - Exhibit VII
• Recycled Materials - Exhibit VIII
• Universal Waste Rule - Exhibit IX
• Generator Requirements - Exhibit X
• Special Management Practices - Exhibit XI
- Tanks
- Containers
EPA Region 2
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Agenda-6
Course Overview (Cont'd)
• Authority
- RCRA Statute...
- RCRA Regulations - 40 CFR
- Federal Register Preambles
- Policy Memos and Guidance
EPA Region 2 8
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Agenda-7
Course Overview (Cont'd)
General comments
- Designed for hazardous waste identification in general,
with hospital examples and pollution prevention tips
added
- Hospital-specific material denoted by
Designed to follow federal not state regulations
EPA Region 2
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Agenda-8
Course Overview (Cont'd)
• Miscellaneous issues \ /
- Course is designed to be interactive
i Questions ) ^~\ /^O
I Examples ^\ \(~)~)
i Case studies —|—-> ^—\
- Promptness - keep on time
- Course evaluations
EPA Region 2
10
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IDENTIFICATION AND
MANAGEMENT OF
REGULATED HAZARDOUS
WASTE
A Workshop Geared Towards
Healthcare Facilities
June 2005
EPA Region 2
-------
Please set all cell phones, pagers,
and PDAs to silent mode
EPA Region 2
-------
Agenda-1
Hazardous Waste & Healthcare
• Healthcare facilities manage many types of waste
- Normal solid waste (paper waste)
- Medical/infectious waste (red bag)
- Hazardous waste ,
- Radioactive Waste .
• These wastes are also regulated by state and local
regulations
EPA Region 2
-------
Agenda-2
Hazardous Waste & Healthcare (Cont'd)
• These wastes are regulated by many federal regulations,
such as I -j —-
- CAA -* —f~~ - CERCLA
- CWA (including oil pollution prevention and storm water)
- DBA I ^ . - FDA
-EPCRA - FIFRA
-NRC ' - OSHA
-RCRA - SDWA
-TSCA
• Today's presentation identifies federal hazardous waste
requirements under RCRA
EPA Region 2
-------
Agenda-3
Hazardous Waste & Healthcare (Cont'd)
• Healthcare issues covered today
- Lab/Storage clean-ups and impact on generator status
- Satellite accumulation areas
- Facility definition and transport between facilities
- Hospital-specific waste issues
i Chemotherapy agents
i Unused pharmaceuticals
i ER use (such as epinephrine and nicotine patches)
i Mercury laboratory wastes
i P- and U-type RCRA-listed wastes
I ETO explosion risk
I Picric acid
EPA Region 2
-------
Agenda-4
Course Overview
Exhibits
• Discarded Material - Exhibit I
• Solid Waste Exclusions - Exhibit II
• Hazardous Waste Exclusions - Exhibit III
--
• Listed Hazardous Waste - Exhibit TV
Delisted Wastes - Exhibit V
"Mixture" and "Derived - From" Rules - Exhibit VI
EPA Region 2
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Agenda-5
Course Overview (Cont'd)
Exhibits
• Hazardous Waste Characteristics - Exhibit VII
• Recycled Materials - Exhibit VIII
• Universal Waste Rule - Exhibit IX
• Generator Requirements - Exhibit X
• Special Management Practices - Exhibit XI
- Tanks
- Containers
EPA Region 2
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Agenda-6
Course Overview (Cont'd)
• Authority
- RCRA Statute...
- RCRA Regulations - 40 CFR
- Federal Register Preambles
- Policy Memos and Guidance
EPA Region 2 8
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Agenda-7
Course Overview (Cont'd)
General comments
- Designed for hazardous waste identification in general,
with hospital examples and pollution prevention tips
added
- Hospital-specific material denoted by
Designed to follow federal not state regulations
EPA Region 2
-------
Agenda-8
Course Overview (Cont'd)
• Miscellaneous issues \ /
- Course is designed to be interactive
i Questions ) ^~\ /^O
I Examples ^\ \(~)~)
i Case studies —|—-> ^—\
- Promptness - keep on time
- Course evaluations
EPA Region 2
10
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Environmental Compliance and Pollution Prevention
Conference for Hospitals
February 26, 2003
Applicability of the Clean
Water Act to Hospitals and
Healthcare Facilities
Philip Greco, CHMM, WSO-CHME
NPDES Program
U.S.E.P.A. Region 2
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CLEAN WATER ACT ("CWA")
Federal Water Pollution Control Act
Protect the Physical, Chemical and
Biological Conditions of Nation's Waters
Established since 1972 and amended
several times thereafter
Role of EPA as the Federal Lead
Agency
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CWA - Definitions
Pollutant - dredged spoil, solid waste, incinerator
residue, sewage, garbage, sewage sludge,
munitions, chemical waste, biological materials,
radioactive materials, heat, wrecked or discarded
materials, rock, sand, cellar dirt, and industrial,
municipal and agricultural waste discharged into
water.
National Pollutant Discharge Elimination System
(NPDES) - A point source program for issuing,
modifying, revoking and reissuance, terminating,
monitoring and enforcing permits, and imposing and
enforcing pretreatment requirements
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CWA - Definitions
Point Source - any discernible, confined and discrete
conveyance, including but not limited to any pipe,
ditch, channel, tunnel, conduit, well, discrete fissure,
container, rolling stock, concentrated animal feeding
operation, or vessel or other floating craft, from which
pollutants are or may be disch
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NPDES Permits
Direct Discharges
• Regulated facility
• Travels through a conveyance system
• Discharge into waters of the U.S.
• Role of State for implementation
• New York (SPDES) - Delegated Program
• New Jersey (NJPDES) - Delegated Program
• Puerto Rico (NPDES) - Non-delegated Program
• Virgin Islands (TPDES) - Delegated Program
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Pretreatment Program
Indirect Discharges
• Regulated facility
• Travels through a conveyance system
• Discharges into Wastewater Treatment Plant
• Control Authority
• Approved Program
• Non-Approved Program
• Role of State for implementation
• New York: Non-delegated Program
• New Jersey: Delegated Program
• Puerto Rico: Non-delegated Program
• Virgin Islands: Non-delegated Program
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Hospitals Source Category for
Direct Discharges
40 CFR Part 460
Hospitals with more than 1,000 occupied
beds
Best Practicable Technology Standards
(BPT)
-Daily Maximum
- Daily Average over 30 consecutive days
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Hospitals Source Category for
Direct Discharges
BPT
- BOD - daily maximum 90.4 lbs/1000 beds
- BOD - monthly average 74.0 lbs/1000 beds
-TSS - daily maximum 122.4 lbs/1000 beds
-TSS - monthly average 74.5 lbs/1000 beds
-pH-6.Oto9.OSU
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Hospitals Source Category for
Indirect Discharges
Pretreatment Program in New York
State is administered by the EPA
Permitting Program
National and Local Pretreatment
Standards
Monitoring and Reporting
Compliance and Enforcement
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STORM WATER DISCHARGES
• Applicability - reference 40 C.F.R. Section
122.26
• Regulation Change - March 10, 2003,
construction site applicability changes from
5 acres to 1 acre
• Point source/combined sewer
• U.S.E.P.A. Contact: Stephen Venezia
(212)637-3856
• U.S.E.P.A. Website:
http://cfpub1.epa.gov/npdes/home.cfm?program_id=6
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Contacts
Philip Greco, U.S.E.P.A. Region 2
Enforcement Specialist
Tel. (212)637-3313
Fax (212) 637-3953
e-mail: areco.
Virginia Wong, U.S.E.P.A.
Pretreatment Coordinator
Tel. (212)637-4241
Fax (212) 637-3953
Underground Injection Control Program: if your facility
discharges into an on site septic system, drywell, etc., UIC
requirements may apply. See enclosed brochure for more
information.
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Environmental Regulation in
New Jersey
A Brief Overview
New Jersey Department of Environmental Protection
Office of Pollution Prevention and
Permit Coordination
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One Stop
Permitting and compliance activities
coordinated through a single point of contact
A coordinated, holistic approach to project
management
Applicable for
- New development projects
- Existing facilities with multi-media impacts seeking
permit renewals or modifications, and
- Brownfields redevelopment projects
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One Stop Benefits
Up-front determination of all significant permits
needed for the project
Coordinated pre-application meetings with all
appropriate regulatory programs
- Agreement on a critical permitting path and schedule for
permit issuance
- Identification and resolution of potentially conflicting
requirements
Multi-media environmental overview site visit
Early opportunities to integrate P2 concepts
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Small Business Assistance
Program
Technical and administrative
support component within the
NJDEP
Confidential multimedia
compliance hotline, including
technical information regarding
permit requirements
- (877) 753-1151 (toll-free)
Not only for small businesses
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New Jersey
Technical Assistance Program
(NJTAP)
Rutgers University
Free
Confidential
Non-regulatory
P2 Clearinghouse
-------
NJTAP
New Jersey Institute of Technology
University Heights
Newark, NJ 07102-1982
Tel. (973) 596-5864
Fax. (973) 596-6367
Email: njtap@megahertz.njit.edu
www.cees.njit.edu/njtap
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Air Pollution Control Code - NJAC 7:27
Subchapter 1 -
Subchapter 2 -
Subchapter 3 -
Subchapter 4 -
Subchapter 5 -
Subchapter 6 -
Subchapter 7 -
Subchapter 8 -
Subchapter 9 -
Subchapter 10
Definitions & General Provisions
Control and Prohibition of Open Burning
Control of Smoke from Fuel Combustion
Control of Particles from Combustion of Fuel
Prohibition of Air Pollution (Odor Provisions)
Control of Particles from Manufacturing Processes
Sulfur Emissions
Permits and Certificates
Sulfur in Fuels
- Sulfur in Solid Fuels
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Air Pollution Control Code - NJAC 7:27
(continued)
Subchapter 11 - Incinerators
Subchapter 12 - Prevention of Air Pollution Emergencies
Subchapter 13 - Ambient Air Quality Standards
Subchapter 14 & 15 - Gas & Diesel Motor Vehicles
Subchapter 16 - Control and Prohibition of VOCs
Subchapter 17 - Control and Prohibition of Toxic Substances^
Subchapter 18 - Emission Offset Rule
Subchapter 19 - Control and Prohibition of NOx
Subchapter 21 - Emission Statements r:C
Subchapter 22 - Operating Permits I I *^
Subchapter 30 - Open Market Emissions Trading
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New Source Review - Sub 8
(609)292-6716
Commercial fuel burning equipment ( > or = 1.0 MM
Btu/hr)
Surface coating and painting operations ( > or = 0.5
gal/hr)
Surface cleaners (degreasers)
Liquid storage tanks ( > 10,000 gal.)
VOC storage tanks ( > or = 2,000 gal.)
Solids storage bins ( > 2,000 cu. ft.)
Dry cleaners
Metal etching and plating tanks (>100 gal)
Incinerators
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New Source Review (continued)
Material handling equipment (conveyors)
Printing and graphics arts operations ( > or = 0.5 gal/hr)
Wastewater and sludge treatment equipment
Solid waste treatment operations ( > 2% solids)
Landfills, transfer stations, recycling, and composting
operations
Non-commercial fuel burning equipment
Control apparatus associated with permitted equipment
Sources emitting toxic substances ( >0.1 Ib/hr TXS)
Equipment processing more than 50 pounds per hour of
raw materials
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Operating Permit - Sub 22
(609) 633-8248
Only Major Source Operations
Thresholds
- TSP, PM-10, SO2, and CO - 100 tpy
- NOX and VOC - 25 tpy
- Lead and any HAP - 10 tpy
- Total HAPs - 25 tpy
- Includes fugitive emissions for 27 selected sources
- Also sources subject to Acid Rain, PSD, and MACT
standards
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Water Supply
Water Allocation (609) 292-2957
- Diversion of > 100,000 gpd
- Temporary De-watering
Well Drilling (609) 984-6831
- Drilling for any reason
- Closing of Wells
Safe Drinking Water (609) 292-5550
- Potable Well for >25 people
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Water Quality
New or Altered WWTPs (609) 633-1179
Point Source Discharges (609) 292-6894 (N)
(609) 984-6840 (S)
- Sanitary/domestic water
- Non-contact cooling water
- Remediated groundwater
- Others (boiler blowdown, floor drains, wash
water)
- Co-mingled stormwater
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Water Quality (continued)
NonPoint Pollution Control (609) 633-7021
- Stormwater Pollution Prevention Planning
- Best Management Practices
Groundwater (609) 292-0407
- Spray Irrigation
- Overland Flow
- Infiltration/Percolator Lagoon
- Surface Impoundment
- Landfill
Pretreatment and Residuals (SLUDGE)
(609)633-3823
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Solid and Hazardous Waste
Solid Waste Management Plan Inclusion (609)
984-5950
Hazardous Waste Management (609)292-7081
Hazardous Waste Permitting (609) 292-9880
- >90 day storage
- Treatment/disposal
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Release Prevention
Toxic Catastrophic Prevention Act (609) 633-
7289
Release and Discharge Prevention (609)633-0610
DDD
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Pesticide Control
(609)530-4070
Application of Pesticides at Aquatic sites
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Radiation Protection
(609) 984-5636
Receive, acquire, process, own, use,
transfer, store, dispose of, distribute,
produce, or transport radioactive material or
waste
Could include
- Particle Accelerator
- X-ray machinery
- Radiation Therapy
- Radio frequency or microwave heated
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Site Remediation
Underground Storage Tanks (609) 633-0708
Industrial Site Evaluation (609) 292-9120
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Land Use
(609) 984-3444
Coastal Area Facility Review Act (CAFRA)
- Are you in a CAFRA area?
Following Activities?
- Waterfront Development Permit
^
- Coastal Wetlands Permit W
- Freshwater Wetlands
- Stream Encroachment Permit
flE
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Land Use (continued)
Pinelands (609) 894-9342
Delaware and Raritan Canal (609) 397-2000
Hackensack Meadowlands (201) 460-1700
Green Acres (609) 984-0631
- Is project under Green Acre Funding? imi
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Natural Resources & Historic
Preservation
Fish, Game and Wildlife (See PIF for #s)
- Does project impact pond, stream, lake, etc.?
Dam Safety (609) 984-0859
- Does project involve the construction, repair or
modification of a dam?
Historic Preservation (609) 984-0140
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Pollution Prevention (P2)
Common Sense
Anywhere a water is discharged, air is released, or
waste is generated, there is an opportunity to do
pollution prevention.
Look at P2 first, Save money and resources
Eliminate or reduce at the source
Get out of the regulation in the first place
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ENVIRONMENTAL
MANAGEMENT SYSTEMS
Commitmen
& Policy
Implementation
& Operation
Continuous
Improvement
Planning
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DEFINITION
An Environmental Management System
(EMS) is a set of management processes,
and procedures that allows an
organization to integrate environmental
considerations into day-to-day decisions
and practices, thereby improving both its
environmental and economic performance
It provides a framework for managing
environmental responsibilities in a more
systematic way.
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EMS GUIDANCES
EMSs: An Implementation Guide for Small and Medium-
Sized Organizations
http://www.epa.gov/owm/iso14001/ems2001final.pdf
EMS Primer For Federal Facilities -
http://esdev.sdc-
moses.com/oeca/ems/details.cfm#fedfac
EMS Guide for Small Laboratpries -
http://www.epa.gov/sbo/labguide.htm
DfE's Integrated EMS Implementation Guide -
http://www.epa.gov/dfe/tools/iemsguide.htm
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EMS GUIDANCES (con't)
Compliance-Focused EMS -
http://esdev.sdc-moses.com/oeca/ems/details.cfmtfems
Commission for Environmental Cooperation: Improving
Environmental Performance and Compliance: 10
elements of Effective EMSs
http://esdev.sdc-moses.com/oeca/ems/details.cfmtfems
Implementation Guide for The Code of Environmental
Management Principles for Federal Agencies (CEMP)
http://esdev.sdc-moses.com/oeca/ems/details.cfmtfems
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ENVIRONMENTAL POLICY
An organization must have a written
environmental policy that clearly communicates
top management's commitment towards a
cleaner environment.
This policy serves as a foundation for the
organization's EMS and provides a unifying
vision of environmental concern by the entire
organization.
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ENVIRONMENTAL POLICY
(Commitments)
Compliance with applicable federal, state, and
local environmental requirements;
Continuous improvement in environmental
performance, including areas not subject to
regulation;
Provide adequate resources to make the EMS
work, including skilled personnel, technology
and financial resources;
Pollution Prevention (e.g., source reduction);
and
Public Outreach/Community Involvement
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STRUCTURE, RESPONSIBILITY,
AND ACCOUNTABILITY
Develop organizational charts that identify
units, management, and other individuals
having environmental performance and
regulatory compliance responsibilities.
Identify and define duties, roles,
responsibilities, and authorities of key
environmental program personnel in
implementing and sustaining the EMS.
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STRUCTURE, RESPONSIBILITY,
AND ACCOUNTABILITY (con't)
Specify the accountability and responsibilities of
management, on-site service providers, and
contractors for environmental protection
practices, assuring compliance, required
reporting to regulatory agencies, and corrective
actions implemented in their area(s) of
responsibility.
Create incentive programs to reward and
recognize employees for excellent
environmental performance.
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STRUCTURE, RESPONSIBILITY,
AND ACCOUNTABILITY (con't)
Outline the potential consequences for departure from
specified operating procedures, including liability for
civil/administrative penalties imposed as a result of
noncompliance.
Designate a management representative who will ensure
that the EMS is developed, implemented, and
maintained.
Environmental responsibilities cannot be confined to an
environmental office; they must be recognized as a
primary responsibility of all employees.
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COMMUNICATIONS
Establish a system for communicating environmental
issues/information internally to all employees, on-site
service providers, and contractors, and externally to
regulatory agencies, customers, neighbors, etc. and a
system for receiving and addressing their concerns.
Effective internal communications require mechanisms
for information to flow top-down AND bottom-up. Method
chosen to receive information/ suggestions from
employees must protect them from negative
repercussions.
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COMMUNICATIONS (con't)
The external communication strategy must
include protocols for:
> responding to inquiries and requests from interested
parties for release of EMS and environmental
performance information; and
> interacting with regulatory agencies regarding
environmental issues and regulatory compliance,
including required reporting.
A more proactive external communications
strategy may result in competitive advantage
and improved community relations.
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ENVIRONMENTAL REQUIREMENTS
& VOLUNTARY UNDERTAKINGS
• EMS should provide a means to identify,
interpret, and effectively communicate
environmental requirements and voluntary
undertakings (e.g., industry codes, EPA's
Partner's for the Environment, CEMP, SGP) to
affected employees, on-site service providers,
and contractors.
• It should include procedures for ensuring that
the organization meets these environmental
requirements and voluntary undertakings.
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ENVIRONMENTAL REQUIREMENTS
& VOLUNTARY UNDERTAKINGS
EMS should also specify procedures for anticipating
changes to environmental requirements — including
new requirements that may apply as a result of
changes in operations — and incorporating those
changes into the EMS.
Resources Available:
> U.S. EPA Region 2's Healthcare Website:
http://www.epa.gov/region02/healthcare/
> EPA Region 2's Compliance Assistance Program:
NY/NJ: (212) 637-3919 or buxbaum.diane@epa.gov
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ENVIRONMENTAL IMPACTS
EMS should contain an ongoing process for
assessing an organization's products, activities,
and services as well as those of its contractors,
and on-site service providers for the purposes of
determining how these products, activities, and
services interact with and impact the
environment as well as determine the
significance of these impacts.
This process should identify activities where
there is a potential for accidents and
emergencies.
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ENVIRONMENTAL IMPACTS
The process should also identify operations and
wastestreams where equipment malfunctions
and deterioration, operator errors, and
discharges or emissions may be causing, or may
lead to:
> releases of hazardous waste or other pollutants to the
environment;
> a threat to human health or the environment; and
> violations of environmental requirements.
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ENVIRONMENTAL IMPACTS (con't)
• The process should provide a mechanism
to:
> keep impact information up-to-date; and
> use the information in setting objectives and
targets, establishing operational controls,
defining monitoring needs and in planning and
designing new processes and products.
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ENVIRONMENTAL IMPACTS
(Implementation Tips)
Develop flow diagrams of your major processes,
Use a cross-functional team to identify impacts.
Trade/professional associations are a good
source of information on where an industry in
general has had past compliance and other
environmental problems.
EPA Region 2 Fact Sheet: Common Violations
and Problems Found at Hospitals
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ENVIRONMENTAL IMPACTS
(Implementation Tips)
Getting Started:
> Look at the wastes you ship off site (whether or not
they are reclaimed or treated). This includes solid and
hazardous waste, and any sludge or liquids you ship
out.
> Note any discharges of water or wastewater to
sewers, drain systems, underground injection wells,
ponds, lakes, streams and groundwater. Run-off from
parking lots and grounds (salt, fertilizer, oils, etc.)
should also be factored in.
> Check for leaks or spills as evidence of poorly
designed and maintained equipment.
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ENVIRONMENTAL IMPACTS
(Implementation Tips)
Getting Started (con't):
> Make a list of your organization's activities, products,
and services that are subject to environmental
requirements.
> Identify potential emergencies/accidents by looking
over current emergency response plans and asking a
series of 'what if questions related to hazardous
materials, activities and processes.
> Consider prior accidents, spills, leaks, incidents and
enforcement actions.
> Check to see if any of your operations are located in
ecologically sensitive areas (e.g., wetlands).
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ENVIRONMENTAL IMPACTS
(Implementation Tips)
Getting Started (con't):
> Factor in land, energy, water, and other natural
resource use into your assessment. What activities,
create the most waste or use the most energy?
> Review your material safety data sheets for toxic or
hazardous materials. Are there more environmentally
friendly alternatives?
> Maintenance activities should be included in your
assessment, including non-routine maintenance such
as tank clean ups.
> Factor in concerns raised by the community such as
noise, odor, dust, traffic, appearance, etc.
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OPERATIONAL CONTROL
EMS should include a process for identifying
activities where documented standard operating
procedures (SOPs) are needed to:
> prevent potential violations or pollutant releases;
> respond to accidents and emergencies; and
> meet your organization's goals.
It should also define a uniform process for
developing, approving and implementing these
SOPs.
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OPERATIONAL CONTROL
(Implementation Tips)
It is important that the people who will implement the
SOPs be involved in drafting them to ensure that they
are accurate and realistic.
Don't reinvent the wheel. Build on informal procedures
and existing SOPs, where possible.
Strive to keep SOPs simple and concise.
The need to plan and control maintenance on equipment
that could cause significant impacts should not be
overlooked
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CORRECTIVE/PREVENTIVE ACTION
& EMERGENCY RESPONSE
• An organization, through its EMS, should
establish procedures for preventing, detecting,
investigating, promptly initiating corrective
action, and reporting any occurrence that may
cause the organization to deviate from its
environmental policy.
• Particular attention should be paid to incidents
that may have an effect on compliance with
environmental requirements as well as on
environmental performance in regulated and
non-regulated areas.
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CORRECTIVE/PREVENTIVE ACTION
& EMERGENCY RESPONSE (con't)
• These procedures should include:
> routine, objective, self-inspections by department
supervisors and trained staff, especially at high
risk/hazard locations identified during the
assessment;
> internal and external reporting of potential violations
and release incidents; and
> investigation and prompt and appropriate correction
of potential violations (The investigation process
includes root-cause analysis of identified problems to
aid in developing the corrective action).
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CORRECTIVE/PREVENTIVE ACTION
& EMERGENCY RESPONSE (con't)
• The procedures should also include:
>a process for mitigating any adverse impacts
on the environment that may be associated
with accidents or emergency situations and
for ensuring that similar incidents are avoided;
>a system for development, tracking, and
effectiveness verification of corrective and
preventative actions; and
>periodic testing of emergency
plans/procedures, wherever practicable.
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MONITORING AND MEASUREMENT
A monitoring and measurement program is
necessary to understand how well an organization's
EMS is working and to help identify steps to improve
the system. This program should include:
> monitoring key characteristics of activities that can
have significant environmental impacts;
> tracking environmental and system performance; and
> evaluating compliance with environmental
requirements.
Compliance evaluation should include periodic
compliance audits by an independent auditor(s).
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VOLUNTARY AUDIT POLICY
The purpose of the Audit Policy is 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.
EPA Region 2's Auditing Website
http://www.epa.gov/region02/capp/cip
John Gorman
EPA Region 2's Audit Policy Coordinator
212-637-4008 or gorman.john@epa.gov
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CORPORATE-WIDE AUDIT
AGREEMENTS
Corporate 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.
If facilities all in Region 2, call John Gorman at
(212)637-4008.
In the case of multi-Regional facilities, call Leslie
Jones at (202) 564-5123.
-------
TRAINING, AWARENESS &
COMPETENCE
The EMS should establish procedures to ensure that all
personnel (including employees, on-site service
providers, and contractors) whose job responsibilities
affect the ability of the organization to achieve its EMS
goals have been trained and are capable of carrying out
these responsibilities.
Particular attention should be paid to personnel
responsible for meeting/maintaining compliance with
environmental requirements and/or whose tasks can
cause significant environmental impacts.
-------
TRAINING, AWARENESS &
COMPETENCE (con't)
All personnel should be aware of the
organization's environmental policy, significant
environmental impacts of their work, their roles
and responsibilities within the EMS, procedures
and environmental requirements that apply to
their activities and what could happen if they
don't follow procedures.
Document training provided.
Train employees on a continuous basis.
-------
ORGANIZATIONAL
DECISION-MAKING & PLANNING
• An EMS should include a process for
performing environmental planning. This
process should:
>require the development of written targets,
objectives, and action plans;
>specify how the action plans will be tracked
and progress reported; and
>evaluate an array of alternatives (pollution
prevention, recycling, control equipment, etc.)
when developing action plans.
-------
ORGANIZATIONAL
DECISION-MAKING & PLANNING
• The EMS should describe how
environmental concerns/issues will be
integrated into organizational decision-
making, including plans and decisions on
capital improvements, product and
process design, training programs, and
maintenance activities.
-------
RECORDS MANAGEMENT &
DOCUMENT CONTROL
EMS should establish procedures to ensure
maintenance of records developed in support of
the EMS.
Basic records management is straightforward,
you need to decide:
> what records you will keep;
> who maintains them and where;
> how long they are kept;
> how they are accessed; and
> how they are disposed.
-------
RECORDS MANAGEMENT &
DOCUMENT CONTROL (con't)
Organization should have document control
procedures in place so that everyone is working
with correct, and up-to-date SOPs, drawings,
and other documents.
These procedures should ensure that:
> EMS documents can be located;
>they are periodically reviewed, updated and approved
for adequacy by authorized personnel;
> obsolete documents are removed; and
> current versions are available where needed.
-------
RECORDS MANAGEMENT &
DOCUMENT CONTROL
(Implementation Tips)
Maintaining your documents and records electronically
allows easy updating and access control, and ensures
that the most up-to-date version of a document is used
by all readers.
Don't reinvent the wheel! Your organization probably has
document controls and record management processes in
place for other business purposes (such as finance,
human resources, or purchasing). Assess how well
these controls work and if they can be adapted for your
EMS.
-------
CONTINUING PROGRAM
EVALUATION AND IMPROVEMENT
• The organization should require periodic
(at least annually) objective evaluations of
the EMS.
These evaluations should be documented
and the results used by management to
bring about improvements in the EMS.
-------
Resources
EPA Region 2's EMS website:
http://www.epa.gov/region02/ems
Healthcare Guide to P2 Implementation through EMSs
by the Kentucky Pollution Prevention Center
EMRs at Federal Facilities
Contact: Kathleen Malone
(212) 637-4083 or malone.kathleen@epa.gov
Environmental Management in Healthcare Facilities,
Edited by Kathryn D. Wagner, PhD
http://www.harcourthealth.com/wbs/index.html
-------
Green Environmental
Management System (GEMS)
Awareness Training
Department of Veterans Affairs
Notes are available when viewing
this presentation in Normal view and Outline view.
-------
VHA Environmental
Management Training
Purpose
VHA Policy on GEMS
Nine Steps for Implementation of GEMS
-------
Purpose
This Veterans Health Administration (VHA)
Directive establishes a program that
requires the development and
implementation of Environmental
Management Systems (EMSs) by VHA
facilities.
-------
Purpose
The primary purpose of the Green
Environmental Management System
(GEMS) is to coordinate existing
environmental programs into one integrated
framework that enhances and improves the
overall efficiency and effectiveness of these
existing, but separate environmental
programs.
-------
Background
Potential Harmful Effects:
• Contamination of surface and runoff water
• Chemical resistant pest populations
• Negative impacts of chemical management
• Toxic effects of chemicals to non-target organisms
• Excessive use of water resources
Loss or degradation of wetland resources
• Financial penalties for non-compliance
-------
What is Green Environmental
Management System?
A management tool to improve
environmental performance.
Accomplished by the identification of roles,
responsibilities & procedures for achieving
prevention, compliance and continuous
improvement.
-------
VHA Policy on Green
Environmental Management
System
Enhancement
Commitment
Compliance
Utilization
-------
Regulatory Requirements Impacting
the Green Management Program
The VHA is responsible for compliance with environmental
regulations that include, but are not limited to the following list:
• National Historic Preservation Act (NHPA) - 1966
" National Environmental Protection Act (NEPA) - 1969 or 1970
» Clean Air Act (CAA) - 1970 & 1990
Federal Insecticide, Fungicide & Rodenticide Act (FIFRA) - 1972
Endangered Species Act (ESA) - 1973
-------
Regulatory Requirements Impacting
the Green Management Program
• Safe Drinking Water Act (SDWA) - 1974
• Resource Conservation and Recovery Act (RCRA) - 1976
• Toxic Substances Control Act (TSCA) - 1976
• Clean Water Act (CWA) - 1977
Comprehensive Environmental Response, Compensation,
and Liability Act (CERCLA/Superfund) - 1980
• Pollution Prevention Act - 1990
• Federal Facilities Compliance Act - 1992
• State and local requirements
-------
VHA and The Environment
Executive Order 13148 - Greening of the Government through
Leadership in Environmental Management 2000:
• Requires all Federal agencies to establish a Comprehensive
Environmental Management System that will reinforce
existing environmental regulations by December 2005.
VHA Roles and Responsibilities:
• Establish a Green Management Program in all VA medical
facilities.
• Resource: Green Environmental Management Guidebook.
-------
Nine Steps in the Development of a
Green Management Program
1. Appoint a Green Coordinator & Designate a Green Committee
2. Train Green Committee
3. Conduct Initial GEMS Gap Analysis
4. Identify Significant Environmental Aspects
. Establish Operational Controls (Develop, Publish and
Distribute GEMS Policies and SOPs)
-------
Nine Steps in the Development of a
Green Management Program
6. Setting and Achieving Objectives & Targets
7. Train Staff on the GEMS Policies and SOPs
8. Conduct Environmental Compliance Baseline
Audit
9. Annual Program Effectiveness Review and Report
-------
STEP 1 - Appoint a Green Coordinator
& Designate Green Committee
GEMS Coordinator ensures the requirements of GEMS are
established, implemented, and periodically reviewed in
accordance with ISO 14001. The Coordinator will report
all results to top management.
GEMS Committee - is a multi-disciplinary committee
established to coordinate and oversee the GEMS. The
committee should have a close liaison with the
Environment of Care or Safety Committee.
-------
STEP 2 - Train GEMS Committee
The GEMS Committee training will include:
GEMS Awareness Training ~ An
implementation course focusing on the
follow-through of the gap analysis process.
-------
STEP 3 - Conduct Initial
GEMS Gap Analysis
Each medical facility will conduct a GEMS
Gap Analysis to identify gaps in the
environmental management system.
The GEMS Gap Analysis is not a regulatory
compliance audit.
All facilities have existing programs to
comply with federal regulations.
-------
What is a Gap Analysis?
Self-assessment - to evaluate the current
environmental program.
Purpose - to help an organization understand
what it is already doing in terms of
requirements for GEMS, and evaluate ways to
build on existing programs and activities
-------
What Questions Does a GEMS
Gap Analysis Address?
1
• How well is the organization and its environmental
programs performing?
• What standards of environmental performance does
the organization hope to achieve?
What are the gaps between objectives and
performance?
What existing programs and activities can serve as
the best foundation for improved environmental
performance?
-------
STEP 4 - Operating Units
Identify Environmental Aspects
1 Aspect - an element of the operating unit's
activities and services that can interact with the
environment.
1 Identify and list all environmental aspects
impacted by the Operating Unit's activities.
.
(use the templates provided in the GEMS Guidebook)
-------
Identification of Environmental
Aspects
The GEMS Committee
will evaluate the
templates and identify
significant
environmental aspects.
1GNIFICANT Objectives
ASPECTS &Targets
-------
Significant Aspects
Based on the assessment, each operating unit will
determine from the list which significant aspects
would have an impact on their operations.
Next, for all those aspects that have a risk
associated with deviation, they will establish
written controls.
Tool used - Standard Operating Procedures (SOPs)
-------
STEP 5 - Establishing Operational
Controls (Develop, Publish and Distribute GEMS
Policies and SOPs)
1. GEMS Committee will develop a GEMS
Medical Center Memorandum (MCM)
2. GEMS Committee review
3. Elimination of discrepancies
-------
Contractors and Suppliers
Operating Units must determine the
significance of the impact contractors and
suppliers will have on operational controls.
Operating Units must communicate with
contractors and suppliers.
Include communication in SOPs.
-------
Operating Unit Reports
Operating unit managers will provide regular
reports to the GEMS Committee containing
the following:
• Overall status report on the GEMS implementation.
• Compliance with environmental regulations.
• Performance standards for employees.
• Action plans for correction of identified deficiencies.
-------
STEP 6 — Setting and Achieving
o o
Objectives & Targets
GEMS Committee selects a few significant
aspects for demonstrating continuous
improvement.
Continuous improvement is dependent on
the success of achieving the objectives and
measurable targets by target date.
Report progress to GEMS Committee.
-------
Setting Objectives and Targets
For each significant environmental aspect
identified within the Operating Units, the
GEMS Committee will set objectives and
targets.
Objectives are a general goal statement.
Target describes in detail how to achieve an
objective.
Targets should be quantitative when practical.
-------
STEP 7 - Train Staff on the
GEMS Policies and SOPs
Training status should be monitored; and refresher
courses should be available periodically.
-------
STEP 8 — Conduct Environmental
Compliance Baseline Audit
The purpose of this audit is to determine the
compliance status of the facility and address
any noncompliance issues.
The GEMS Committee will address any
noncompliance items with an action plan for
immediate compliance and a tracking
mechanism.
Compliance audits are usually conducted by
external experts.
-------
STEP 9 - Annual Program
Effectiveness Review and Report
The final steps in developing a GEMS include
the following:
• Determine program measurement criteria.
• Set up an internal assessment process.
• Establish a management review process.
Emphasis on continual improvement
-------
Measurement Criteria
(Environmental Performance Indicators)
Purpose: The indicators focus on how well the
overall system for improving environmental
management is functioning.
Performance indicators will determine the
effectiveness of the GEMS implementation
and various components.
-------
Measurement Criteria
(Environmental Performance Indicators)
To measure results effectively, methods must be:
" Simple
• Flexible
" Consistent
• Ongoing
• Usable (i.e., results communicated)
• Accurate (i.e., reliable data produced)
-------
Internal Assessment Process
Purpose: Develop information for management
review and to take corrective action where needed,
Assessments are conducted through the following:
* Interviews
* Examination of documents
* Observation of activities & review of results of
measurements
Assessments should be conducted annually.
-------
Senior Management Review
and Approval Process
The Medical Center Director will review
and evaluate the environmental
management system at defined intervals.
A comprehensive Annual Review must be
conducted by the GEMS Committee and
approved by the Medical Center Director.
-------
Senior Management Review
and Approval Process
The Annual Program Effectiveness Review must
cover the following elements:
1 Status report on regulatory compliance program.
1 Status report on GEMS implementation.
1 Review of the accomplishments of the
Targets & Objectives.
1 Committee proposals of changes/
improvements in GEMS program.
-------
EPA Region 2 Healthcare
Compliance Initiative
-------
Basis for the Initiative
Source of toxic chemicals such as phthalates, and
persistent, bioaccumulative toxics such as mercury
and dioxin;
Generators of a wide variety of hazardous wastes;
Produce two million tons of solid waste;
Contribute to air pollution (e.g., smog, air toxics,
depletion of ozone layer); and
Not complying with environmental requirements.
-------
Goals
• Hospitals will comply with environmental
requirements.
• Hospitals will develop Environmental Management
Systems - http://www.epa.gov/region02/ems
• Mercury-containing waste will be eliminated from
the hospital waste stream by 2005.
• The volume of all hospital waste generated will be
cut in half by 2010.
-------
Integrated Strategy
Provide environmental assistance to healthcare
facilities.
Encourage healthcare facilities to perform voluntary
compliance audits and enter into corporate audit
agreements.
http://www.epa.gov/region02/capp/cip
Conduct Inspections and take enforcement, if
necessary.
-------
Environmental Assistance
Hold regulatory and pollution prevention
workshops.
Establish focus groups in NY, NJ, &
Caribbean
Develop compliance assistance tools
http://www.epa.gov/region02/healthcare
-------
Enforcement
Unannounced inspections will be conducted
at hospitals (both single and multi-media).
Appropriate enforcement will be taken - from
notice of violation to criminal prosecution.
Implementation of a supplemental
environmental project may reduce penalties.
http://www.epa.gov/region02/p2/sep.htm
-------
Steps to Achieving and Maintaining
Compliance
• Commitment from top management
• Commit sufficient resources
• Include environmental compliance in
outreach
• Implement an Environmental Management
System (EMS)
• Conduct periodic environmental compliance
audits
-------
EPA Region 2 Contacts
Diane Buxbaum
EPA Region 2 Compliance Assistance
Coordinator for Healthcare Facilities
(212) 637-3919 or buxbaum.diane@epa.gov
John Gorman
EPA Region 2 Audit Policy Coordinator
(212) 637-4008 or gorman.iohn@epa.gov
-------
Environmentally Preferable
Purchasing for Hospitals
Colleen Keegan RN
Health Care Without Harm
P I T A L S
fora
HEALTHY
NVIRONMEN'
3/31/2014
-------
The Mission of Health Care
Without Harm
•To transform the health care industry so it is no longer a source
of environmental harm by eliminating pollution in health care
practices without compromising safety or care.
H O U T H *
fc
3/31/2014
-------
What is EPP?
Environmentally Preferable Purchasing
(EPP) is the act of purchasing
products/services whose environmental
impacts have been considered and
found to be less damaging to the
environment and human health when
compared to competing
products/services.
Consideration of the environmental
impacts during each stage of a product's
life cycle.
3/31/2014
-------
Why EPP?
Purchasing is the Key
Purchasing departments are the
central point for nearly every
product or service procured for the
hospital. This makes it an effective
point to apply actions to improve
environmental impact. It is at this
stage of money transfer and
contract development that vendors
can best be influenced.
3/31/2014
-------
Benefits of EPP
significantly improve impact on the overall quality
of the environment
reduce costs due to lower overhead, avoided
waste disposal, liability costs or occupational
health costs
provide healthier environment for patients, staff
Leverage positive publicity for institution
3/31/2014
-------
Why is it less costly to make
improvement at the point of
purchase?
Correcting a problem close to its
source is less costly than taking
action downstream. This is what
EPP is all about. If the
environmental impact can be
addressed as early as possible,
overall costs will ultimately be
lower than pollution abatement
later on.
3/31/2014
-------
Consider a mercury
thermometer:
• If one buys a mercury-free thermometer,
the cost of preventing mercury from
being introduced to the environment is
merely the cost of the thermometer.
• But, if a mercury thermometer is
purchased and it breaks, the cost now
includes the hazardous material clean-
up. If the mercury thermometer is placed
in the trash - the cost of preventing
mercury from entering the environment
includes pollution prevention equipment
on the incinerator. At each step, the cost
multiplies rapidly.
3/31/2014 7
-------
How Costs Increase the
Further Downstream a
Problem is Addressed
0
O
O!
_C
'
ra
QJ
i_
u
c
$1009
$513
$35
X
•^vi
^•4-.
ps-1--
.•,S;V •
,:3*.v
Cost of pollution
control for incinerator
Clean up cost of broken
mercury device
Differences in cost between
mercury and aneroid devices
3/31/2014
Referenced. Galligan, SHP, using data from Mercury Elimination and Reduction
Challenge (MERC), "Mercury in the Health Care Sector: The Cost of Alternative
Products", November, 1996, pp 14-24
8
-------
What are the characteristics of an
Environmentally Preferable Product?
Less Toxic (mercury-free)
Fewer Allergens (latex-free)
Less Packaging (buy in bulk)
Polyvinyl Chloride -free
Recycled content (paper)
Reusable (mattresses)
Energy Efficient (appliances)
3/31/2014
-------
Purchasing Policy
Development
Request support for EPP goals from top
management in the form of policy statement,
Request for Proposal (RFP) language, job
descriptions, or other support.
Develop policies and procedures to ensure
the implementation of the environmentally
preferable purchasing practices.
3/31/2014 10
-------
Purchasing Policy
Purchasing
Policy affirms
commitment to:
Conservation
Waste Reduction
Recycling
Reuse
Waste Elimination
3/31/2014 11
-------
Setting Up the
Environmentally Preferable
Purchasing (EPP) Team
An EPP team is comprised of hospital
professionals from different areas
working together to foster a new
purchasing culture. This team
coordinates its activities with the facility-
wide environmental team and the
product review committee. The leader of
the team should be someone whose
administrative responsibilities include
ensuring that the EPP Project is fully
implemented.
3/31/2014
12
-------
Members of the EPP
Team might include
Central Services
Clinical Staff: Nursing, Medicine, Surgery
Communication/Public Relations
Environmental (Ecology) Team
Environmental Services
Facilities Operations (Physical plant, operations, security)
Financial Services (Accounting)
Food Services
Group Purchasing Organization (GPO)
Infection Control
Laboratory services
Materials Management (purchasing, contracting and
services)
Risk/Safety Management
/Housekeeping
-------
Determining Goals of the EPP Team
Consult with facility environmental team to
determine where EPP may help the institution fulfill
the institution's main environmental goals.
Determine what concerns or burning environmental
issues a hospital already has. Tackling an existing
problem, such as mercury spills, environmental
violations, or occupational health problems often
guarantees support at all levels.
3/31/2014 14
-------
n setting goals, examine available
resources (see handouts) that can help
you implement actions to achieve your
goals.
• Decide on environmentally preferable
purchasing goals that are specific,
measurable, and to be completed in a
set time period.
3/31/2014 15
-------
Examples of Measurable
Goals
• Increase purchase of recyclables or
reusables 30% by the next fiscal year.
• Reduce packaging waste or total solid
waste 20% in 12 months.
• Reduce energy or water use 10% every
six months for 5 years.
• Reduce purchase of products that
become hazardous waste by 10% in next
contract.
• Reduce purchase of mercury-containing
products 80% by next year.
3/31/2014 16
-------
Investigate various methods of
implementing an EPP program
Creating a Preferred Vendor Program
Creating Lists of Preferred Products or
Chemicals to Avoid
Working with a GPO (Group Purchasing
Organization)
3/31/2014 17
-------
Environmentally Preferable
Purchasing (EPP)HOW TO"
Do EPP in Hospitals"
a step-by-step guide for piloting a
Durcnasmg project - on your
landout.
0 S. P I T A L S
fora
H EALTHY
ENVIRONMENT^
3/31/2014 18
-------
You can make a
difference!
There is a direct link between healing the individual
and healing the planet.
By carefully selecting goods and services, healthcare
organizations can significantly impact the overall
quality and health of the environment.
3/31/2014 19
-------
Exhibit I
Discarded Material
Overheads from Presentations
RCRA Policy Excerpts
EPA Region 2
-------
Exhibit I-1
Statutory Definition
RCRA §1004 (27) states:
• The term "solid waste" means any garbage, refuse, sludge
from a waste treatment plant, water supply treatment plant,
or air pollution control facility and other discarded material,
including solid, liquid, semisolid, or contained gaseous
material.
•A common mistake is to forget that RCRA defines solid and hazardous waste. It is particularly important to understand the statutory definition of solid
waste. Under RCRA, a solid waste can be a liquid or a gas.
EPA Region 2
-------
Exhibit 1-2
Discarded Material
A material is a solid waste if it is discarded
261.2(a)(l)
•The regulations begin in a deceptively easy manner.
EPA Region 2
-------
Exhibit 1-3
Discarded Material
• Abandoned
• Recycled
• Inherently waste-like
261.2(a)(2)
•Very straight-forward definition in the regulations.
•Definitions to follow.
EPA Region 2
-------
Exhibit 1-4
Abandoned
• Disposed of
• Burned or incinerated
• Accumulated, stored, or treated before, or instead of, being
disposed, burned, or incinerated
261.2(b)
•Again, very straight forward definition.
•Basic approach is if you intend to get rid of it, it is abandoned.
EPA Region 2
-------
Exhibit 1-5
Abandoned
• Does the facility have a use for the material?
• Does the facility treat the material as if it was a valuable
commodity? ^
• Does the facility give it to someone else that has a use for it?
261.2(b)
•Again, very straight forward definition.
•Basic approach is if you intend to get rid of it, it is abandoned.
EPA Region 2
-------
Exhibit 1-6
EPA Region 2
-------
Exhibit 1-7
EPA Region 2
-------
Exhibit 1-8
EPA Region 2
-------
Exhibit 1-9
Recycled
Specific types of recycled materials are
considered discarded
- Used in a manner constituting disposal
- Burned for energy recovery J^^^^
- Reclaimed J
- Accumulated speculatively
A material is also considered discarded if it is
accumulated, stored or treated before recycling
v /
261.2(c)
•We'll go into more detail when we discuss recycling later.
•Used in manner constituting disposal - placed on the land, such as road oiling, dust suppression if material was not produced to be placed on the land.
•Burned for energy recovery - burned to gain energy, such as steam, from wastes with high Btu values.
•Reclaimed - processed to recover a usable product.
•Speculative accumulation. If less than 75% of a waste is recycled in a calendar year, it is being speculatively accumulated.
EPA Region 2
10
-------
Exhibit I-10
Inherently Waste-Like 261.2(d)
• Certain wastes are considered hazardous even when recycled
• These are materials that pose a threat to human health and the
environment when recycled
• So far, only dioxin containing wastes have been designated as
inherently waste-like
- F020, F022, F023, F026, F028
F021, unless it is used at the site of generation
261.2(d)
•These are wastes that have no potential for further use.
•Ones now listed are dioxin-containing wastes.
•The Administrator will list additional wastes for cause based on the following criteria:
- Materials are ordinarily disposed of, burned or incinerated.
- Materials contain Appendix VIII constituents not ordinarily found in raw materials - or products for which the materials substitute - and are not used or
reused during recycling.
- Materials may pose a substantial hazard to human health and the environment when recycled.
•No other wastes have been proposed.
•Secondary materials added February 21, 1991 FR.
^^^^^^^H
EPA Region 2 11
-------
Exhibit I-11
Appropriate Documentation
Must Be Provided
• Respondents who claim that a certain material is not a solid waste, or is
conditionally exempt from regulation, must demonstrate a known
market or disposition and that terms of exclusion or exemption are met
• In plain English, that means you need:
Documentation (such as contracts) showing that a second person
uses the material as an ingredient in a production process
If recycling, must show that they have the necessary equipment
Don't buy more than you need.
261.2(f)
•The regulated community holds the burden to demonstrate that his or her material does not meet the criteria to be considered a solid waste. This includes
test results, equipment and other documentation supporting his or her claim.
EPA Region 2 12
-------
Exhibit I-12
Relevant Federal Regulations
40 CFR Part 261
SubpartA 261.1(c) - ,
261.2
EPA Region 2 13
-------
Exhibit I-13
RCRA Policy Excerpts
EPA Region 2 14
-------
Exhibit II
Solid Waste Exclusions
(Most don't apply to hospitals. General Reference.)
Overheads from Presentations
Relevant Federal Regulatory Citations
RCRA Policy Excerpts
EPA Region 2
-------
Exhibit II-1
A Discarded Material Is Not A Solid Waste If It Is
Specifically Excluded From Regulation
261.4(a)
•The regulations specifically exclude certain materials from being considered solid waste.
•Many of these exclusions are specified inRCRA - the statute.
•There are also certain materials which are recycled and are not considered solid waste - those will be discussed under the recycling section of this training
manual.
EPA Region 2
-------
Exhibit II-2
Solid Waste Exclusions
• Domestic sewage, and any mixture of domestic sewage and
other wastes, that passes through a sewer system to a POTW for
treatment (307(b) of CWA)
Industrial wastewater discharges that are point source discharges
subject to regulation under Section 402 of the Clean Water Act
Irrigation return flows
Source, special nuclear or by-product materials as defined by the
Atomic Energy Act. Some radioactive wastes are regulated
under RCRA, such as mixed wastes.
1), (2), and (3)
•Domestic sewage refers to untreated sanitary wastes.
•The exclusions are because domestic sewage and industrial sewage are managed under the Clean Water Act.
•Note however, that the exclusion for industrial waste waters does not apply to the system -just the end of pipe.
•This exclusion applies only to the actual point discharge, not to wastewater while being collected, stored, or treated, or to sludges generated by industrial
wastewater treatment.
•Irrigation return flows may carry pesticides which meet the definition of "discarded commercial chemical products" but the waters are regulated under the
Clean Water Act.
EPA Region 2
-------
Exhibit II-3
Solid Waste Exclusions (Cont'd)
Definition of mixed waste: waste that satisfies the definition of low-level
radioactive waste (LLW) in the Low-Level Radioactive Waste Policy Amendments
Act of 1985 (LLRWPAA) and contains hazardous waste that either (1) is listed as a
hazardous waste in Subpart D of 40 CFR Part 261 or (2) cause the LLW to exhibit
any of the hazardous waste characteristics identified in Subpart C of 40 CFR Part
«,.
In Region 2, NY and NJ have authority to regulated mixed waste (PR and the VI
do not).
Typical hospital mixed waste includes spent radiopharmaceuticals and nuclear
medicine, http://www.uic.coi
Most hospitals store mixed wastes until they are no longer considered radioactive
and dispose of them properly. If you opt to dispose of mixed waste while still
radioactive, make sure you send it to a suitable treatment facility (e.g., one that is
NRC approved). 261.4(a)(4)
• AEA exclusion was specified in RCRA. The waste exclusion resulted in a controversy regarding wastes which are both radioactive and meet the definition of
RCRA-regulated hazardous waste. On July 3, 1986, EPA issued a clarification in the Federal Register that stated that the exclusion was limited to
radionuclides - not the entire waste matrix. The FR notice also explained that states must obtain authorization for mixed wastes. Until then, mixed wastes
were not regulated in already-authorized states. As of 10/1/2003, 48 states had mixed waste authorization and 2 states were unauthorized.
EPA Region 2 4
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Exhibit II-4
Solid Waste Exclusions (Cont'd) -
Not Hospital Related
• Materials subjected to in-situ mining techniques and which
remain in the ground
Pulping liquors reclaimed in pulping liquor recovery furnace
and then reused in the pulping process, unless accumulated
speculatively
• Spent sulfuric acid usedQjrp£§duce virgin sulfuric acid,
unless accumulated speculatively
261.4(a)(5),(6),and(7)
•In-situ means the wastes never see the light of day - they basically stay where they began.
•These second two exclusions are the results of effective lobbying effort by the paper and chemical industries. Basically, these wastes are regularly
reclaimed and reused in the process in which they are generated.
EPA Region 2
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Exhibit II-5
Solid Waste Exclusions (Cont'd) -
Not Hospital Related
• Secondary materials reclaimed and returned for reuse to
original process in which they were generated, provided:
- Only tank storage is involv<
- Closed process
- Reclamation does not involve controlled flame combustion
- Less than 12 months accumulation prior to reclamation
r ^—^
- Reclaimed material is notjjsee-ta produce a fuel
- Reclaimed material is not used in a manner constituting
disposal
261.4(a)(8)
•This exclusion is intended to provide a more general exclusion to exempt materials which are normally returned to the process in which they were
generated. The conditions which apply are meant to make sure they don't get out into the environment. If they do - they lose their exclusion and are
considered solid wastes.
EPA Region 2
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Exhibit II-6
Solid Waste Exclusions (Cont'd) -
Not Hospital Related
• Spent wood preserving solutions that have been used and
are reclaimed and reused for their original intended purpose
When used as a fuel, coke and
steel industry that contain or a
tank tar sludge (K087)
tar from the iron and
uced from decanter
261.4(a)(9)and(10)
EPA Region 2
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Exhibit II-7
Solid Waste Variance
• Opportunity to obtain case-by-case variances from a
Regional Administrator found under
- 260.30
- 260.31
- 260.33
Possible situations
- Materials accumulated speculatively without sufficient
amounts recycled
- Materials reclaimed and reused within original process
- Materials incompletely reclaimed
•If a material doesn't meet one of the specific exclusions in 261.4(a), the regulations provide the regulated community with a variance.
•The variance, in 260.30, notes the above situations in which, on a case-by-case basis, a material may still be excluded from being defined as a solid waste.
•The Regional Administrator makes the decision based on criteria set out in 260.31 and in accordance with procedures found in 260.33.
EPA Region 2 8
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Exhibit II-8
Relevant Federal Regulations
40 CFR Part 260
260.30
260.31
40 CFR Part 261
261.4(a)
EPA Region 2
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Exhibit III
Hazardous Waste Exclusions
(Most don't apply to hospitals. General Reference.)
Overheads from Presentations
Relevant Federal Regulatory Citations
RCRA Policy Excerpts
EPA Region 2
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Exhibit III-1
A Solid Waste May Be Excluded As A Hazardous Waste
261.4(b)
•The regulations also specifically exclude certain solid wastes from being considered a hazardous waste.
• Some of these exclusions are specified in the RCRA statute; others are the result of effective lobbying efforts and participation in the regulatory
development process.
EPA Region 2
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Exhibit III-2
Hazardous Waste Exclusions
• Household Waste
- A resource recovery facility managing municipal solid waste is not
managing hazardous waste as long as:
i The facility receives and burns only household waste or solid
waste from commercial or industrial sources that does not
contain hazardous waste
i The facility does not accept hazardous wastes
• Waste from university dormitories and military bases also fall under the
exclusion, but not nursing homes
facilities)
which are considered healthcare
Note: Healthcare, dental, and laboratory facilities on
bases and in dormitories are not excluded
261.4(b)(l)
•Household waste includes garbage, trash, and sanitary wastes in septic tanks from single-family houses, apartment buildings and hotels, ranger stations.
crew quarters, campgrounds, picnic grounds, and day-use recreation areas.
•Clarification of the household waste exclusion was provided by Congress in HSWA.
EPA Region 2
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Exhibit III-3
Other Hazardous Waste Excluded from
Regulation - Not Hospital Related
• Samples of solid waste or samples of water, soil, or air collected for the
sole purpose of testing to determine their characteristics or composition,
during storage or transportation
• Samples collected for the purpose of treatability studies during storage
or transportation
Samples undergoing treatability studies at laboratories and testing
facilities. Note: After analysis is complete, samples are regulated if
listed or characteristic.
To qualify for these exemptions, a shipper must comply with the proper
shipping requirements (DOT, USPS, and any other requirements)
261.4(d),(e),(f)
•These three exclusions are intended to facilitate analysis necessary to determine the regulatory status of a waste or the ability of a process to treat a waste.
•These exclusions apply only in limited situations.
^^^^^^^H
EPA Region 2
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Exhibit III-4
Hazardous Waste Exclusions (Cont'd)
• Used chlorofluorocarbon refrigerants from totally enclosed heat transfer
equipment, provided the refrigerant is reclaimed for further use
Injected groundwater that is hazardous only because it exhibits the
Toxicity Characteristic, (Waste Codes DO 18 through D043 only) that is
reinjected through an underground injection well pursuant to the phase
ma in
en at c
hydrocarbon recovery undertaken at certain petroleum facilities until
January 25, 1993
Petroleum-contaminated media and debris that fail the toxicity
characteristic and are subject to UST Corrective Action regulations
261.4(b)(ll)and(12)
•The petroleum-contaminated media exclusion is intended to avoid duplication of regulation, since the waste is covered under the UST regulations.
•Injected groundwater added October 5, 1990 and revised April 2, 1991.
•Chlorofluorocarbons added February 13, 1991.
EPA Region 2
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Exhibit III-5
Hazardous Waste Exclusions (Cont'd) -
Not Hospital Related
• Solid waste generated by any of the following and which are
returned to soils as fertilizers
- Growing and harvesting of agricultural crops
- Raising of animals, including animal manures
Mining overburden returned to the mine site
261.4(b)(2)and(3)
All of these exclusions have historic reasons.
•In 1976, when RCRA was enacted, the US was faced with problems in the agricultural area and did not want to place additional burdens on farmers.
•Mining overburden exemption is similar to the solid waste exclusion; the solid waste exclusion if the overburden never "sees the light of day," the
hazardous waste exclusion is provided if the wastes are created above-ground, but returned to the place in which it was mined.
EPA Region 2
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Exhibit III-6
Hazardous Waste Exclusions (Cont'd) -
Not Hospital Related
• Fly ash waste, bottom ash waste, slag waste, flue gas
emission control waste generated primarily from
combustion of gas or other fossil fuel except as provided by
266.112 for facilities that burnpr process hazardous wastes
lgt_3r
• Drilling fluids, produced waters, and other wastes
associated with the exploration development, or production
of crude oil, natural gas, or geothermal energy
261.4(b)(4)and(5)
•In 1976, when RCRA was enacted, the US also faced problems in the energy area.
•Therefore many wastes generated by these industries obtained exemptions.
•These wastes must still be managed as solid waste in accordance with Subtitle D requirements.
EPA Region 2
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Exhibit III-7
Hazardous Waste Exclusions (Cont'd) -
Not Hospital Related
• Wastes which fail the test for the toxicity characteristic because
chromium is present, or are listed due to the presence of chromium, as
long as no other constituent is present
• Specific wastes generated from the leather trimming and finishing
industries which meet the chromium exclusion
^-ai "L-^ ^ 261.4(b)(6)
•These exclusions resulted from additional information received by EPA after the original promulgation of the regulations in 1980.
•These exclusions apply mostly to the leather tanning industry.
•EPA is re-examining these exclusions to determine if they should remain. The reason is that the new toxicity characteristic uses total chromium - not just
trivalent chromium. The Agency has obtained new data showing that, under certain circumstances, trivalent chromium converts to hexavalent chromium.
•For the first exclusion [261.4(b)(6)(i)] the following additional criteria must be met:
- Chromium is exclusively trivalent chromium.
- Waste is generated from an industrial process which uses trivalent chromium.
- Process does not generate hexavalent chromium.
- Waste is typically and frequently managed in non-oxidizing environments.
•For the second exclusion [261.4(b)(6)(ii)], the specific excluded wastes are:
- Chrome trimmings.
- Chrome shavings.
- Buffing dust.
- Sewer screenings and wastewater treatment sludges.
- Waste scrap leather.
- Wastewater treatment sludges from the production of TiO2 pigment.
EPA Region 2 8
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Exhibit III-8
Hazardous Waste Exclusions (Cont'd) -
Not Hospital Related
• Certain solid waste from the extraction, beneficiation, and
processing of ores and minerals (including coal), including
phosphate rock and overburden from the mining of uranium ore,
except as provided by 266.112 for facilities that burn or process
hazardous wastes
Cement kiln dust, except as provided by 266.112 for facilities that
burn or process hazardous waste^ „
Discarded wood treated with arseni
the test for toxicity
products which fail
261.4(b)(7),(8),(9)and(10)
•The first exemption is the Bevill Amendment. EPA has amended this exemption which we will discuss in a moment.
•Cement kiln dust exclusion continues to be of concern, mainly because of the ability of cement kilns to properly manage hazardous wastes by burning for
energy recovery. Wastes from other thermal treatment activities are not provided the same automatic exclusion.
•The wood treatment exclusion also includes the condition that the wood waste is not hazardous waste for any other reason and the waste is generated by
persons who utilize the arsenic-treated wood for the intended end use. This exclusion was an attempt to remove from regulation materials and
management practices (that are basically the same as using the materials) which do not pose extreme hazards to human health or the environment.
EPA Region 2
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Exhibit III-9
Hazardous Waste Exclusions (Cont'd) -
Not Hospital Related
• Bevill Amendment
- Solid waste from the extraction, beneficiation, and
processing of ores and minerals (including coal),
including phosphate rock and overburden from the
mining of uranium ore, except as provided by 266.112
for facilities that burn or process hazardous wastes
261.4(b)(7)
•This was the original statutory language.
•EPA originally interpreted the exclusion very broadly.
•EDF sued EPA to force them to clarify and limit the exclusion; the American Mining Congress countersued.
•Results - EPA amended regulatory language to: (a) set criteria for wastes to qualify for the exclusion and (b) clarify which wastes were excluded from the
exclusion (i.e., included in the Subtitle C program).
EPA Region 2
10
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Exhibit III-10
Hazardous Waste Exclusions (Cont'd) -
Not Hospital Related
Bevill Amendment Criteria for Exclusion
- Must be a mineral processing waste
- Must be generated in high volume
Must be of low hazard
261.4(b)(7)
•Mineral Processing wastes are defined as materials which:
- Are solid waste as defined by EPA.
- Are uniquely associated with mineral industry operations.
- Originate from mineral processing and possess certain attributes.
•High volume are mineral processing wastes which:
- For non-liquids, are generated at an annual rate of > 45,000 metric tons/year/facility.
- For liquids, are generated at an annual rate of > 1 million metric tons/year/facility between 1983 and 1988.
•Low hazard, high volume mineral processing wastes are excluded if:
- Waste extracts (using SW-846, method 1312) contain concentrations of certain inorganics < 100 times MCL at 2 or more facilities - with certain
additional caveats.
- Constituent concentrations are used to determine facility-level values using certain criteria.
EPA Region 2
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Exhibit III-11
Relevant Federal Regulations
40 CFR Part 261
261.4 (b)
EPA Region 2
12
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Exhibit IV
Listed Hazardous Waste
Overheads from Presentations
Relevant Federal Regulatory Citations
RCRA Policy Excerpts r
EPA Region 2
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Exhibit IV-1
A solid waste may be a regulated
hazardous waste if it is either:
Listed
or
Characteristic
EPA Region 2
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Exhibit IV-2
Is The Solid Waste Listed As A Hazardous Waste?
* ^v
EPA Region 2
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Exhibit IV-3
Lists Of Hazardous Wastes
• Identified in 40 CFR Part 261 Subpart D
• Lists include industrial waste streams and waste
commercial chemical products that typically
- Exhibit one or more hazardous waste characteristics
- Contain hazardous constituents
• Wastes are identified by a single letter prefix (F, K, P, or U)
followed by a three digit number
EPA Region 2
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Exhibit IV-4
Lists Of Hazardous Wastes
• Non-specific sources (§261.31) - "F" wastes
• Specific source (§261.32) - "K" wastes (not hospital
related)
• Discarded commercial chemical products, off-specification
materials, residues in containers, and spill residues
(§261.33)- "P" and "U" wastes
- "P" wastes - acutely hazardous waste
- "U" wastes - toxic hazardous waste
EPA Region 2
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Exhibit IV-5
F-Listed Wastes
Wastes from non-specific sources
Spent solvent wastes
Electroplating wastes - not hospital related
Petroleum refinery oil/water separation floats and sludges
not hospital related *jt
§261.31
•The spent solvent wastes will be discussed in greater detail.
•Electroplating wastes include specific:
- plating bath solutions.
- wastewater treatment sludges.
- plating bath residues.
•See 51 FR 43350 (December 2, 1986) for information on the F006 listing (revision).
•See 55 FR 5340 (February 14, 1990) for information on the F019 listing.
EPA Region 2
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Exhibit IV-6
F-Listed Wastes (Cont'd)
Wastes from non-specific sources (cont'd) - not hospital
related
• Dioxin-containing wastes ^
Chlorinated aliphatic hydrocarbon production wastes
Hazardous waste landfill leachate
Spent formulations from wood preserving processes
§261.31
•The dioxin-containing wastes were promulgated on January 14, 1985 (50 FR 1978).
•The chlorinated aliphatic hydrocarbon production wastes were promulgated (F025) and revised (F024) on December 11, 1989 (54 FR 50968).
•The landfill leachate listing was promulgated as part of the land disposal restrictions program (third-third rule, June 1, 1990, 55 FR 22520).
•Wastes from wood preserving (some dioxin-containing) were promulgated on December 6, 1990 to comply with consent decree resulting from EOF suit
over pentachlorophenol.
^^^^^^^H
EPA Region 2 7
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Exhibit IV-7
F001-F005 Listings
Cover only solvents used for their solvent properties, as in
degreasing, cleaning, fabric scouring, use as diluents,
extractants, reaction and synthesis media
Do not cover products disposed of which are produced
using solvents as ingredients in the production process.
Example: do not include paints, inks and adhesives. Note:
This applies to manufacturers of paints, not to consumers
buying paint off the shelf, ^r
§261.31
•Interpretation of the solvent listings generated a great deal of confusion in the past.
•See the December 31, 1985 Federal Register notice (50 FR 52126) for a discussion of solvent uses and the listings.
EPA Region 2 8
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Exhibit IV-8
F001-F005 Listings (Cont'd)
The F001, F002, F004, and F005 listings include all spent solvent
mixtures containing a total of 10% or more (by volume) of all of the
solvents listed under those waste codes
The 10% threshold is applied to the solvent mixture before use.
The F003 solvents are listed for ignitability only; the 10% threshold
does not apply
fv
Examples of healthcare F-listed wastes include:
Solvents that are used in research laboratories, pharmacies, and
morgues
Methanol, acetone, methylene chloride, and others
§261.31
•Note the language of the F001-F005 listings regarding mixtures. This language was added onDecember 31, 1985.
•See the December 31, 1985 Federal Register notice (50 FR 52126) for a discussion of solvent mixtures.
•Prior to this revision, the listings were interpreted to include only single ingredient solvents.
EPA Region 2
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Exhibit IV-9
K-Listed Wastes - Not Hospital Related
Wastes from specific sources
• Identified by industry:
- Wood preserving ^
- Production of inorganic pigments
- Production of veterinary pharmaceuticals (this does not
apply to human pharmaceuticals)
EPA Region 2 10
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Exhibit IV-10
K-Listed Wastes (Cont'd)
Not Hospital Related
Wastes from specific sources (cont'd)
• Identified by industry (cont'd):
- Production of organic chemicals
- Production of inorganic chemicals
- Production of pesticides
- Petroleum refining W
Ink formulation
EPA Region 2 11
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Exhibit IV-11
K-Listed Wastes (Cont'd) -
Not Hospital Related
Wastes from specific sources (cont'd)
• Identified by industry (cont'd):
- Production of explosives
- Production of iron and steel
- Production of primary metals (smelting wastes)
- Coking ^\
• Healthcare facilities generally do not produce this type of
waste
•The history of the smelting wastes listings is very convoluted (K064-K066, K088, K090, K091).
- Most recently, the Agency relisted those wastes as hazardous on September 13, 1988 after determining that they were not within the scope of the mining
waste exclusions (53 FR 35412).
- The U.S. Court of Appeals remanded all the listings except K088 (spent potliners) to the Agency for further consideration and explanation.
EPA Region 2 12
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Exhibit IV-12
P- And U-Listed Wastes
• Section 261.33 lists over 350 commercial chemical products
which are hazardous when discarded
- P-listed wastes are known as acute hazardous wastes
(§261.33(e))
- U-listed wastes are known as toxic hazardous wastes
(§261.33(f)) ,£>
§261.33
•Products are hazardous wastes only when discarded (i.e., when they are first determined to be solid wastes) by virtue of being abandoned (i.e., disposed of
burned or incinerated, or accumulated prior to disposal, burning, or incineration), recycled, or inherently waste-like (§261.2).
EPA Region 2 13
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Exhibit IV-13
P- And U-Listed Wastes (Cont'd)
The phrase "commercial chemical product or manufacturing chemical
intermediate having the generic name listed in ..." refers to a chemical
substance which is manufactured or formulated for commercial or
manufacturing use which consists of the commercially pure grade of the
chemical, any technical grades of the chemical that are produced or
marketed, and all formulations in which the chemical is the sole active
ingredient. It does not refer to a material such as a manufacturing process
waste, that contains any of the substances listed in paragraph (e) or (f).
Where a manufacturing process waste is deemed to be a hazardous waste
because it contains a substance listed in paragraph (e) or (f), such waste will
be listed in either 261.31 or 261.32 or will be identified as a hazardous waste
by the characteristics set forth in subpart C of this part.
§261.33
•Products are hazardous wastes only when discarded (i.e., when they are first determined to be solid wastes) by virtue of being abandoned (i.e., disposed of
burned or incinerated, or accumulated prior to disposal, burning, or incineration), recycled, or inherently waste-like (§261.2).
EPA Region 2 14
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Exhibit IV-14
P- And U-Listed Wastes (Cont'd)
• Unused chemical substances (e.g., pharmaceuticals)
• Pure or technical grade chemical formulations
• Formulations in which the chemical is the sole active
ingredient
I
§261.33
•See the comment after §261.33(d) for an explanation of the commercial chemical product listings.
•See also discussion on 55 FR 22671 (June 1, 1990, the third third and disposal restrictions rule).
•Sole active ingredient means that the chemical is the reason the production works. For example, the residue from a pesticide listed in 261.33(f) would be
considered a sole active ingredient even if it were mixed with a carrier (such as water). Therefore, it would be considered a discarded commercial
chemical product. Nail polish which contains toluene, however, would not be considered a discarded commercial product because it is not the unique
chemical active in the nail polish.
EPA Region 2
15
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Exhibit IV-15
P- And U-Listed Wastes (Cont'd)
• Off-specification commercial chemical products or
manufacturing chemical intermediates
• Residues of the above materials remaining in "non-empty"
containers
• Residues, contaminated soil, water, or debris resulting from
clean-up of spills of above materials
§261.33
•The presence of one or more of the P or U listed chemicals in a process residue or wastewater does not, in and of itself, make that substance a P or U
listed waste.
•A proposal to regulate mixtures of P listed wastes based on toxicity was never promulgated (February 13, 1986, 51 FR 5472).
EPA Region 2
16
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U-Listed Wastes
Exhibit IV-16
Ethylene Oxide (U11
Chloral Hydrate (U034)
Chlorambucil (U035)
Cyclophosphamide (U058)
Acrylonitrile (U009)
Daunomycin (U059)
Melphalan(UlSO)
Acetyl Chloride (U006)
Aniline (U012)
Azaserine (UO15
EPA Region 2
17
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U-Listed Wastes (Cont'd)
Exhibit IV-17
MitomycinC(UOlO)
Streptozotocin (U206)
Bromoform (U225)
CacodylicAcid(U136)
Carbon Tetrachloride (U211)
Diethylstilbesterol (U089)
Lindane (U129)
Saccharin (U202) |
Chlornaphazin (U026)
p-Chloro-m-Cresol (U039)
EPA Region 2
18
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Exhibit IV-18
U-Listed Wastes (Cont'd)
Selenium sulfide (U205)
Uracil mustard (U23 7)
2-Chloroethyl Vinyl Ether (U042)
Creosote (U051)
Cresols (U052)
Warfarin < 0.3% (U248)
Resorcinol (U201) mm_
Paraldehyde(U182)
Dichlorobenzenes (U070, U071, U072)
Ethyl Acetate (U112)
EPA Region 2
19
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Exhibit IV-19
U-Listed Wastes (Cont'd)
Mercury (U15
Phenacetin(U187)
Formic acid (U123)
Acetone (U002)
Reserpine (U200)
Chloroform (U044)
Hexachlorophene (U132)
N-butyl alcohol (U031)
Formaldehyde (U122)
Cyclophosphamide (U058)
EPA Region 2
20
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U-Listed Wastes (Cont'd)
Exhibit IV-20
*
Ethyl Carbamate (U238)
EthylEther(U117) ^F
Hexachloroethane (U131)
Maleic Anhydride (U147)
Methanol(U154) I
Methylpyrilene (U155)
3 -MethyIchloranthrene (U15 7)
Methylthiouracil (U164)
Naphthalene (U165)
Phenol (U 18 8)
EPA Region 2
21
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Exhibit IV-21
U-Listed Wastes (Cont'd)
Tetrachloroethylene (U210)
Trichloroethylene (U228)
Thiram (U244)
Dichorodifluromethane (U075)
Trichloromonofluromethane (U121)
EPA Region 2
22
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Exhibit IV-22
P-Listed Wastes
Epinephrine (P042
Arsenic Trioxide (P012)
Nicotine (P075)
Arsenic (PO12)
Cyanide Salts (P030) I
Osmium Tetroxide (P087)
Nitroglycerin(P081)
Phentermine (P046)
Physotigmine (P204)
EPA Region 2
23
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Exhibit IV-23
P-Listed Wastes (Cont'd)
ysotigmine salicylate (PI8
Warfarin > 0.3% (POO 1)
Phenylmercuric Acetate (P092)
Sodium Azide (PI05)
Strychnine (PI08) I
3-Benzyl Chloride (P028)
Chloropropionitrile (P027)
Potassium Silver Cyanide (P099)
EPA Region 2
24
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Exhibit IV-24
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
Sodium azide is a rapidly acting, potentially deadly chemical that
exists as an odorless white solid
When it is mixed with water or an acid, sodium azide changes
rapidly to a toxic gas with a pungent (sharp) odor
It also changes into a toxic gas when it comes in contact with solid
metals (for example, when it is poured into a drain pipe containing
lead or copper)
The odor of the gas may not be sharp enough to give people
sufficient warning of the danger
EPA Region 2 25
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Exhibit IV-25
Chemotherapy Wastes
Eight are U-listed:
Chlorambucil (Leukeran) (U035)
Cyclophosphamide (Cytoxan, CTX, Neosar, Procytox) (U058)
- Daunomycin (Daunorubicin, Cerubidine, DaunoXome,
Rubidomycin, Liposomal Daunorubicin) (U059)
Diethylstilbestrol (Di
Stilbesterol)
tilbesterol, DBS, Stilbestrol, Honvol,
- Mitomycin C (Mitomycm, Mutamycin) (U010)
Streptozotocin (Streptozocin, Zanosar) (U206)
- Uracil Mustard (U23 7)
EPA Region 2
26
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Exhibit IV-26
Chemotherapy Wastes (Cont'd)
• One is P-listed:
Arsenic Trioxide (Trisenox) (P012)
EPA Region 2
27
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Exhibit IV-27
Chemotherapy Wastes (Cont'd)
• Other listed drugs used in cancer research or treatment;
but not FDA approved:
- Azaserine (UO15)
- Chlornaphazin (U026)
- Ethyl Carbamate (U238)
- 3 -MethyIcholanthrene (U15 7)
•/ \ s
EPA Region 2 28
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Exhibit IV-28
Chemotherapy Wastes (Cont'd)
Operating Room
^Mitomycin eye drops, bladder irrigant (U-listed)
Medical-Surgical Floors^K sr^
^Immunosuppressives, e.g., Rheumatoid arthritis
4Methotrexate (Not listed) ^ I
^Cyclophosphamide (U listed)
Emergency Department
^Ectopic pregnancy
^Methotrexate
Pediatrics
Urology Clinics
EPA Region 2 29
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Exhibit IV-29
Chemotherapy Wastes (Cont'd)
Tablets/Capsule
+ Chlorambucil
Vial - Powder
+ Cyclophosphamide
4> Melphalan
Vial - Liquid
+ Fluorouracil (Not listed)
Ampule- Liquid
+ Arsenic Trioxide
EPA Region 2
30
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Exhibit IV-30
Chemotherapy Wastes (Cont'd)
• Over 100 chemotherapy agents not regulated by EPA
• Examples:
4> Alkylating agents: Cisplatin, Thiotepa
4> Antimetabolites: Fluorouracil, Methotrexate
4> Hormonal (antiandrogen): Lupron® (leuprolide)
+ Hormonal (antiestrogen): Tamoxifen
+ Mitotic Inhibitor: Taxol® (paclitaxol)
EPA Region 2
31
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Exhibit IV-31
Bulk & Trace Chemo
These terms do not exist in the federal
regulatory prograrrlK
nv\ <-D
Mixture rule applies to listed chemo wastes (see
40CFR§261.3(a)(2)(iv))
No minimum quantity or concentration to exit
regulatory system
EPA Region 2 32
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Exhibit IV-32
Future Listings
• No healthcare-related listings are currently proposed
• Possible future listings may include new pharmaceuticals,
such as new chemotherapy drugs, but none are planned
EPA Region 2 33
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Exhibit IV-3 3
Proposed Regulation
• EPA proposed a rule November 20, 2003 to modify regulation
of certain shop towels contaminated with listed solvents. This
rule is expected to be finalized in June 2008
• Rule applies to certain solvent-contaminated materials, such as
reusable shop towe^^^^disposable wipes and paper towels.
• http://www.epa.gov/epaoswer/hazwaste/id/solvents/wipes.htm
EPA Region 2 34
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Exhibit IV-34
Proposed Regulation (Cont'd)
• Rule would conditionally exclude:
- From the definition of hazardous waste: disposable
industrial wipesltbat are/contaminated with hazardous
1 1 CVN^T-^ (dtloS !
solvents and are going to disposal
From the definition of solid waste: reusable industrial
shop towels and rags that are contaminated with
hazardous solvents and are sent for laundering or dry
cleaning
EPA Region 2 35
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Exhibit IV-3 5
Proposed Regulation (Cont'd)
• Rule would apply to:
- Industrial wipes exhibiting a hazardous characteristic (i.e.,
ignitability, corrosivity, reactivity, or toxicity) due to use
with solvents cpSL
- Industrial wipes contaminated with F001-F005 spent F-
listed solvents or comparable P- and U-listed commercial
chemical products that are spilled and cleaned up with
industrial wipes
• http://www.epa.gov/epaoswer/hazwaste/id/solvents/wipes.htm
EPA Region 2 36
-------
Exhibit IV-3 6
Used Oil and Fuel in Underground
Storage Tanks
• Used oil is not a RCRA-listed waste but is subject to storage requirements under
the CWA
• You must have a Spill Prevention, Control, and Countermeasure Plan (SPCCP) if
you*:
Have oil storage capacity of > 1,320 gallons above ground or
42,000 gallons of oil capacity below ground
55-gallon drums and other above-ground storage containers less than 55-
gallons are exempt from the 1,320 storage capacity determination
*EPA updated these quantity determinations in August 2002
Hospital Examples
• Emergency generator tanks
• Gas tanks for fleet vehicles such as ambulances
EPA Region 2 37
-------
Exhibit IV-3 7
Important Resources
• Healthcare Environmental Resource Center (HERC)
•www.hercenter.org
•Provides information for the healthcare sector on:
• Pollution prevention; and
Compliance assistance
EPA Region 2 38
-------
I A I T II V
•
o treat
Healthy
ommunTtii
Hoiiltlicare
Environmental
Resource
Center
arardous Materials Regulated Medical Waste Waste Reduction Facilities & Equipment Regulations & Standard
-
AboutH2£
Partners Program
Champions Program
State Programs
Awards
Teleconferences
Ltstserv
Technical Resources
H2E News & Events
Library
Contact H2E
Website
operated by:
ncnb
Welcome to HERC-the
Healthcare Environmental
Resource Center
HERC provides pollution prevention and
compliance assistance information for the
healthcare sector. The site is being compiled
from a wide variety of resources and is not
complete yet. In the meantime, please look
through the material that has been developed
to date, and help us get this right. We welcome
your feedback on its layout, design, content,
and ease of use. You can send your comments
and suggestions to Kelly Heekin at H2E.
For more information on the website, contact:
Paul Chalmer. NCMS (734) 995-4911 or
Laura Brannen. H2E (603) 795-9966 or
Chen Wen. EPA (202) 564-8849
NEWS & EV
HOT TOPICS
Mercury
can be
found in
many
common
health care devices, from
fever thermometers,
blood pressure cuffs,
and esophageal dilators,
to mercury-containing
motion switches,
fluorescent light bulbs,
and cleaning solutions.
When mercury-
containing devices are
improperly disposed of
(in red bags or down the
drain, for example), they
can cause significant
human health and
environmental problems.
More...
Cougle
Google Search
Exhibit IV-3 8
-------
Exhibit IV-3 9
Important Resources
• Profile of the Healthcare Industry
•http://www.epa.gov/compliance/resources/publications/assi
stance/sectors/notebooks/health.html
40
-------
Exhibit IV-40
Important Resources
List of lists
- List of chemicals subj ect to:
1 EPCRA302
i CERCLA hazardous substances
i EPCRA313and
i CAA112(r)
- Includes RCRA listed wastes
^,
- http://www.epa.gov/ceppo/pubs/title3.pdf
- Searchable database at: http://130.ll.53.73/lol/
EPA Region 2 41
-------
Exhibit IV-41
Important Resources (Cont'd)
• RCRA Online Database
• The RCRA Online database is designed to enable
users to locate documents, including publications and
other outreach materials, that cover a wide range of
RCRA issues and topics
• Searchable database at: http://www.epa.gov/rcraonline
EPA Region 2 42
-------
Exhibit IV-42
Important Resources (Cont'd)
• RCRA Hot Line 1 -800-424-9346
• The RCRA Hot Line, operated by an EPA contractor,
provides answers to questions posed by the regulated
community and can help you locate EPA guidance
documents and policies
• The RCRA Hotline covers the following statutes:
- EPCRA
- CERCLA^
EPA Region 2 43
-------
Exhibit IV-43
Important Resources (Cont'd)
• Interpretive Document Collection
* www.epa.gov/guidance
• Provides a central point of access to non-
binding general policy, guidance, and
interpretive documents that describe how the
Agency intends to exercise its discretionary
authority and explains what a statute or
regulation means
EPA Region 2 44
-------
Exhibit IV-44
Important Resources (Cont'd)
NIOSH Alert
http://www.cdc.gov/niosh/docs/2004-165/
Purpose: To increase awareness among
health care workers and their employers
about the health risks posed by working with
hazardous drugs and to provide them with
measures for protecting their health.
EPA Region 2
45
-------
Exhibit IV-45
Important Resources (Cont'd)
• Managing Pharmaceutical Waste: A 10-Step
Blueprint for Health Care Facilities In the
United States
• http://h2e-online.org/docs/h2epharmablueprint41506.pdf
EPA Region 2
46
-------
Exhibit IV-46
Important Resources (Cont'd)
• PharmEcology Associates
- Commercial service
- Offers on-site reviews
- Gives seminars on best practices in managing
hazardous pharmaceutical waste
- Includes a searchable database of pharmaceutical
products (over 107,000 drug items) and applicable
regulatory requirements
^^^^^
- http://www.pharmecology.com
EPA Region 2
47
-------
Exhibit IV-47
il P harm Eco logy - Microsoft Internet Explorer
File Edit View Favorites Tools Help
I
Pharmacology
Environmental Consultation to the Healthcare
A 2Q04 H2E "Champion for Change "Award Winner
CONTACT US
MYCOLOGY
Pharm@i» Waste
Wnard Subscribers
Einnil:
I jmccauley @tousarch .cd
P.isswoul:
Remember me
Phsrm©'" Waste
Wizard Signup
SUBSCRIBE
To or Pharm@CDiogy'ffi
Forgot your Password?
News Alert:
RESOURCES
SITE MAP
SERVICES
Pharm@™ Formulary Analysis
Gut started by identifying your
hazardous waelo Pharmaceuticals
PharmfF™ Waste Wizard
KCL'p Ufi-tu-dale tin-lino with
our weekly database updates
Establishing =
compliant and
cost-effective
procedures
to manage
pharmaceutical
waste.
Do-Site Risk Assessment
r>h«l nut how youi cutront phArmdceuLicut
miiKHjumonl (ir«cticc«i can be improved
Pharm©™ Policies and Procedures
Usl out EPA Resource Cousinvjlrun and Rocovery Act (RCRAI
compliant tomptaies to upgrnctti yout policies and procedures
PharmEcoltMiy© Announces a New Brand, a New Wizard,
and New Waste Categories!
JOO Soutb ExaculivB Diive, Suils 101 - Broofcfield. Wiiconsin 53005 • TEL: 262 B14.2«35 • FAX: 414.479.9911 - iifoSphtrmflCOloBy.com
Privacy Stalament Tenths and Condilions, W«d Mar'30th, 2005 3:35 PM.
48
-------
Exhibit IV-48
3 PharmEcology - Microsoft Internet Explorer
File Edit View Favorites Tools Help
[- linifx
I
Pharm (&cology ASM™KS, LLC
^mental Consultation to the Healthcare- Industry"*
CONTACT US
SITE MAP
Welcome : James McCauley
hnrrnEeology Associates, LLC.
Bi ool
-------
Exhibit IV-49
3 PharmEcology - Microsoft Internet Explorer
File Edit View Favorites Tools Help
- linifxi
i
Pharmacology •'„„„„„„. uc
Providing Environmental Consultation ta the Healthcare Industry"'
CONTACT US
ffi*
SITE MAP
RESOURCES
Welcome: Jame-s McCauley
Phai mEcoloqy Associates, LLC.
Brookfield.WI
Analysis f01: Wisconsin^
_ Foil 01 u)
Ha; nidiiii!.- Waslu
PfiiMillE
•* Hazardous™ Waste
Individual Product Search
Addition.il Intoi ni
Federal Hazardous Waste
Product: 00008-0263-01 EPItlEPHRIIIE IIIJ IMG ML
Generic: Epinephiine HCI
Manufacturer: WVETH
NtW SEARCH
1.00 ML Rx
DEA: llon-Conti oiled
Haurtfuu*
Wastd
J
Recommended Waste Classification
Regulated as federal hazardous waste:
P042-Epinephrine
Recommended Waste Stream
Handle as hazardous waste:
Toxic
What Products are in the
Database ?
How Does the Search
i Logic Work?
What Is "PtiarmE
Hazardous™ Waste"?
Product Questions?
Contact Us
Logout
200 Sflulh ExiCUllv* Drive. Sull« 101 • Brookfiold, Wisconsin 53005 - TEL 262 8K.2635 • FAX: 4M 479.9911 • Jnfa@pblrraBcalogy.cam
,.i-/.-, i ,,•'• .,- PtivstyStawmcnL Terms and Candilioiis, W«d ito 30th, 2005 3-47 PM
50
-------
Exhibit IV-50
File Edit View Favorites Tools Help
Pharmacology __^_
••tmefilai Cvnsuliatitjn to the Healthcare Industry*
CONTACT US
ffi
SITE MAP
I'jcr*
ftESUURCES
j'Ef! VICES
Welcome: .lames McCauley
IPtiarmEicology Associates, LLC,
Braokfield.WI
Analysis for: WISCONSIN
Frilnial
H«r iniu
rrfi
Wast*
Wastu
What Products are in the
Database?
How Does the Search
Logic Work?
What Is "PAarmE
Hazardous™ Waste"?
Product Questions?
Contact Us
Logout
Indrvidual Prodi*
Additional Information
Federal Hazardous Waste
1.00 ML Rx
1.00 MG/ML
Product:
Full name:
Reference:
Page:
00008-0263-01 EPINEPHRINE INJ IMG ML
EPIIJEPHR1HE HCL TUBEX
eFACTS (Facts & Comparisons Online)
Epinephrine
Epinephrine, is a P listed chemical, defined by USEPA as acutely hazardous waste when
present as the sole active ingredient (P042).
Other then the exception noted below, all containers that have held P-listed waste must be
managed as hazardous waste unless triple rinsed. If triple rinsed, all rinsate must also be
treated as hazardous waste. The rinsed RCRA-empty container may then be disposed of
as non-hazardous waste.
Based on a 1994 USEPA Hotline Report, epinephrine residue in a syringe used for
administration is not regulated as a hazardous waste. The syringe is considered a
"dispensing instrument", and, therefore, the contents were used for their intended purpose.
51
-------
Exhibit IV-51
3 PharmEcology - Microsoft Internet Explorer
: File Edit View Favorites Tools Help
I
Pharmacology
'nmental Consultation to the Healthcare- Industry*
CONTACT US
SITE MAP
wtw
lAHMrtS1 OOLOGY*
RESOURCES
Welcome: James McCauley
PharmEcology Associates, LLC.
Bi oohfield.Wl
Analysis for: WlSCOtlSlli
Change Stirte
Change Password
What Products are in
the Database?
How Does the Search
Logic Work?
Wliat Is "PftataiE
Hazardous™ Waste"?
Product Questions?
Contact Us
Logout
liKlivklu.il Product Search
Search By NDC Number
Batch Product Search
PharmEcology Admin
NEWSCAHCM
IIDC number:
(For example: 1234*45610 or 1234-456-10 or 1234-456)
Search by Product Name
Product name:
Strength ( optional):
Rheumatrex
Search by Genetic Name or Active lugredieiil
Genei ic name:
Manufacturer (optional): Strength!optional):
*HilltS
1. Enter a full or partial MDC number, with 01 withoirt hyphens
2. Enter a full 01 partial pi oduct 01 generic name
3. Enter the beginning of the strength, ignoring the concentration or additional ingredients
SEARCH »
if
200 Soulh Ejiscmiva Dflve. Sulle >0l • Braabtiald, Wisconsin 530Q5 • TEL: 2G2.814.2635 • FAX: 414..479.9941 > lnfa@phirniBcalo9y.ceni
• ' Pn»ac-yStalB«wtBt Terms and Conditions. Wed Mar 30th, 20053:47 PM.
52
-------
Exhibit IV-52
H P harm Eco logy - Microsoft Internet Explorer
File Edit View Favorites Tools Help
r7
Pharmacology
__ . Providing Environmental Consultation to the Heailncafe Industry"1
CONTACT US
SITE MAP /1\.
Welcome : James Me Cauley
harmEcology Associates, LLC.
indhmlual Product Search
Analysis for: WISCONSIN
~\ Change State
Please select a specific NDC number to review.
How Does the Search
Logic Work?
What Is "PtiattttE
Product Questions?
Contact Us
Logout
EA
EA
00005-4507-07 -™ 16.00 EA
Methotrexate Sodium (An
20.00 EA
24.00 EA
fl.fl«tA
12.00EA
Methotrexate Sodium (An
00005-4507-91
67253-0580-42
67253-0580-43
RHFIIMATRFY TAR
Methotrexate Sodium (An
RHEUMATREX TAB 2.5
Methotrexate Sodium (An
RHEUMATREX TAB 2.5MG
Methotrexate Sodium (An
Manufacturer
DEA Status
STADA
PHARMACEUTICALS,
Non-Controlled
STADA
PHARMACEUTICALS,
Non-Controlled
STADA
PHARMACEUTICALS,
Non-Controlled
STADA
PHARMACEUTICALS,
Non-Controlled
STADA
PHARMACEUTICALS,
Non-Controlled
STADA
PHARMACEUTICALS,
Non-Controlled
STADA
PHARMACEUTICALS,
Non-Controlled
Rx
Rx
Rx
Rx
Rx
Rx
Rx
53
-------
Exhibit IV-53
'H PharmEcology - Microsoft Internet Explorer
File Edit View Favorites Tools Help
I
Pharmacology
Associates, LLC
CONTACT US ffif SITE MAP
Providing fnvirpnmenlai Consultation to the Healthcare Industry*
Welcome: Jamee MeCauley
'hnrmEcology Associates, LLC.
Biooh field. V/l
Analysis for: WISCONSIN
Change State
Change Password
What Products are in
the Database ?
How Does the Search
Logic Work?
What Is "PftatmE
Hazardous™ Waste"?
Product Questions?
Contact Us
Logout
Individual Product Search
Please select a specific NDC number to review.
00005-4507-04
00005-4507-05
00005-450707
00005-4507-09
00005-4507-91
67253-0580-42
67253-0580-43
Description
Generic Nome
RHEUMATREX TAB 2.5MG
Methotrexate Sodium (An
RHEUMATREX TAB 2.5MG
Methotxexate Sodium (An
RHEUMATREX TAB 2.5MG
Methotrexate Sodium (An
RHEUMATREX TAB 2.5MG
Methotrexate Sodium (An
RHEUMATREX TAB 2.5MG
Methotrexate Sodium (An
RHEUMATREX TAB 2.5MG
Methotrexate Sodium (An
RHEUMATREX TAB 2.5MG
Methotrexate Sodium (An
Manufacture!
DEA Status
STADA
8.00 EA PHARMACEUTICALS,
Non-Controlled
STADA
12.00 EA PHARMACEUTICALS,
Non-Controlled
STADA
16.00 EA PHARMACEUTICALS,
Non-Controlled
STADA
20.00 EA PHARMACEUTICALS,
Non-Controlled
STADA
24,00 EA PHARMACEUTICALS,
Non-Controlled
STADA
8.00 EA PHARMACEUTICALS,
Non-Controlled
STADA
12.00 EA PHARMACEUTICALS,
Non-Controlled
Hx
Rx
Rx
Rx
Rx
Rx
54
-------
Exhibit IV-54
'it PharmEcology - Microsoft Internet Explorer
File Edit View Favorites Tools Help
Pharmacology
Associates, LLC
CONTACT US
ffi*
SITEMAP
JinvitgQinentai Constipation to the Healthcare industry'"
tl'Miii
..
- i
-
Welcome : James McCjuley
Pharmacology Associates. LLC.
Brookfield.Wl
Analysis for: WISCONSIN
PfrflHIlE
Hat.Mfa
Nun hi28)iluits
lndivulu.il Product Search
Additional Information
NIW SEARCH
tt.UO EA Rx
2.50 MG
What Products are in the
j. J*
*
How Does the Search
Logic Work?
What Is "PharmE
Hazardous™ Waste"?
Product Questions?
Contact Us
Logout
PhiimiE Hazardous™ Waste
Product: 00005-4507-04 RHEUMATREX TAB 2.5MG
Full name: RHEUMATREX
Reference: eFACTS (Facts & Comparisons Online)
Page: Methotrexate Sodium Monograph
NIOSH - AnTiiieoplnstics
A NIOSH Hazardous Drug Alert was initially released on March 25, 2004 as a result of
the efforts of the NIOSH Hazardous Drug Working Group. The 1990 ASHP definition
of hazardous drug was expanded to include the following categories: carcinogenicity,
teratogenicity or other developmental toxicity, reproductive toxicity, organ toxicity at low
doses, genotoxicity, and structure and toxicity profiles of new drugs which mimic existing
drugs as determined hazardous by the above criteria. Based on these expanded
definitions, this antineoplatic drug has been listed as a hazardous drug in Appendix A of
the Hazardous Drug Alert. Best management practices encourage handling as a "Risk
Management" toxic hazardous waste.
For additional information, refer to:
http://www. c dc. gov/mo sh/do c s/2 0 04 -HazDrugAlert/ff
z
55
-------
Pharmacology
Exhibit IV-5 5
• LLC
CONTACT US ffi* HELP ? SITE MAP A\
Providing Environmental Consultation to the Healthcare Industry*
ABOUT PHAflMECOLOGY*'
Welcome. Phil Qlsort
Community Medical Center
St.. Paul, MN
Ana!/sia for. M trine sola
Individual Product Searcht
Federal Hazardous Wasto
Additional Information
IDSEflVICES
NEW SEARCH
\
ferfsrol
Hazardous Wasin
Risk
Hazardous Wasiu
Haiaidous
What Products aia ia
ilia Database?
How Does the Search
Logic Wotk?
is
Management™*
Product
Contact Us
Logout
«- -i i ;-ii.:,;v ' Associates, LLC. AH rights r«saivqd V»uw our privacy siamm»nt.
Sat Oci 12lti. 20(12 9:0? AM
EPA Region 2
56
-------
Exhibit IV-56
Important Resources (Cont'd)
• Green Pharmacy Program
- Comprehensive overview of ideas for the stewardship of
Pharmaceuticals and personal care products
- http://web.archive.org/web/20030622105213/http://www.epa
.gov/esd/chemistry/ppcp/greenpharmacy.htm
University of Kentucky Cancer Registry
Comprehensive list of chemotherapy agents and their
^j ^^^*-_.
abbreviations
- http://www.kcr.uky.edu/manuals/abstractor/appendix h.pdf
EPA Region 2
57
-------
Exhibit IV-57
Important Resources (Cont'd)
• Other websites for information on drugs:
- http://www.drugdigest.org
- http://www.rxlist.com/
- http ://www. drugs. com/
• FDA's List of Approved Oncology Drugs
- http://www.fda.gov/cder/cancer/approved.htm
• List of websites with information on MSDS:
- http://hazard.com/msds/links.html
EPA Region 2
58
-------
Exhibit IV-5 8
Important Resources (Cont'd)
LS
i EA LTH Y
V I R O N M E X T '
Hospitals for a Healthy Environment - H2E
The primary goal of the H2E effort is to
educate health care professionals about
pollution prevention opportunities in
hospitals and health care systems
http://www.h2e-online.org
Hazardous waste info at: http://www.h2e-
online.org/tools/chem-hwm.htm
Pharmaceutical waste info at:
http://www.h2e-online.org/tools/chem-
pharm.htm
EPA Region 2
59
-------
Exhibit IV-59
Important Resources (Cont'd)
Sustainable
HOSPITALS
Sustainable Hospitals
Provides technical support to the healthcare
industry for selecting products and work
practices that reduce occupational and
environmental hazards, maintain quality
patient care, and contain costs
Includes a searchable database of alternative
products
http://www.sustainablehospitals.org
EPA Region 2
60
-------
Exhibit IV-60
Important Resources (Cont'd)
Healthcare Without Harm
Health Care Without Harm is an
international coalition of 443 organizations
in 52 countries working to transform the
health care industry so it is no longer a
source of harm to people and the
environment
http://www.noharm.org
EPA Region 2
61
-------
Exhibit IV-61
Important Resources (Cont'd)
OSHA Hospital eTool
A web-based training tool on
occupational safety and health issues for
hospitals
http://www.osha.gov/SLTC/etools/
hospital/mainpage.html
EPA Region 2
62
-------
Exhibit IV-62
Relevant Federal Regulations
40 CFR Part 261
261.30 - 261.33
EPA Region 2 63
-------
Exhibit IX
Universal Waste Rule
Overheads from Presentations
Relevant Federal Regulatory Citations
Other Guidance
\^p^k w
RCRA Policy Excerpts
EPA Region 2
-------
Exhibit IX-1
Universal Waste Rule
EPA finalized the Universal Waste Rule on May 11,1995
- Done to streamline recycling efforts for commercial and
industrial groups. Exempts hazardous wastes that are
generated domestically as well
- Universal wastes are not regulated under full RCRA
Subpart C, but rather by streamlined Universal Waste
Rules (40 CFR 273)
EPA Region 2
-------
Exhibit IX-2
Universal Waste Rule (Cont'd)
The universal waste rule exempts the following:
- Hazardous waste batteries
- Hazardous waste thermostats (mercury containing
thermostats)
- Certain lamps
Certain hazardous waste pesticides
EPA Region 2
-------
Exhibit IX-3
Universal Waste Rule (Cont'd)
• States have autonomy when it comes to the Universal Waste
Rule:
- States do not have to adopt it
- States can add or remove wastes
- States can also have more stringent requirements
- NY uses federal guidelines for Universal Waste
*—'
NJ has state guidelines for Universal Waste Rule and
includes computer monitors (CRTs) as universal wastes
- Federal rule applies in VI JV
- PR has not adopted the Universal Waste Rule
EPA Region 2
-------
State Universal Waste Rules
Exhibit IX-4
Federal Types of Universal Waste Categanes
Stale-Only Wastes in Additem to Federal Universal Wastes
Universal Waste Regulations Do Not Apply (Not Adopted or Authorized)
EPA Regions Implement Universe I Waste Regulations
http://www.epa.gov/epaoswer/hazwaste/id/univwast/uwsum.htm
EPA Region 2
-------
Exhibit IX-5
State Universal Waste Rules (Cont'd)
'Aerosol Cans (CO);
'Antifreeze (LA, NH);
'Ballasts (MD, ME, VT);
'Cathode Ray Tubes (CRTs) (ME, MI, NH, RI);
' Electronics (CO, CT, NJ);
1 Oil-Based finishes (NJ);
EPA Region 2
-------
Exhibit IX-6
State Universal Waste Rules (Cont'd)
Mercury Related Universal Wastes
• Mercury-Containing Devices (CO, MA, MI, ND, NH, NJ,
PA, RI);
. Barometers (NH, RI);
• Gas Flow Regulators (NH);
• Intact Mercury-Containing Ampules (NH);
• Manometers (NH, RI);
• Mercury Switches (MI) and Relays (NH, RI);
• Mercury Thermometers (MI);
• Sphygmomanometers (NH, RI);
• Thermocouples (NH, RI);
• Thermometers (NH, RI); and
• Water meters (NH).
EPA Region 2 7
-------
Exhibit IX-7
Examples of Hospital Universal Waste
Nickel cadmium or sealed lead-acid batteries found in
Electronic equipment
Mobile phones
Laptop computers
Emergency back up lighting
Mercury-containing thermostats
Lamps that have a hazardous component
Fluorescent lights
High intensity discharge lamps
Neon lamps
Mercury vapor lamps
High pressure sodium lamps
Metal halide lamps
EPA Region 2
-------
Exhibit IX-8
Proposed Rule
• Proposed rule - June 12, 2002
• Exclusion from the definition of solid waste which would
streamline RCRA management requirements for used CRTs
and glass removed from CRTs sent for recycling
• Also sought comment on streamlining management
requirements for used mercury-containing equipment by
adding it to the federal list of universal wastes
• Rule was finalized and effective as of 8/5/05 for both CRTs
v. r.
nng equipment.
paoswer/hazwaste/id/uni vwast.htm
UaQL
EPA Region 2
-------
Exhibit IX-9
Types of Universal Waste Handlers
• Small Quantity Universal Waste Handlers
(SQHUW) accumulate less than 5,000 kilograms
(11,000 Ibs) of all universal waste categories at any
one time.
• Large Quantity Universal Waste Handlers
(LQHUW) accumulate 5000 kilograms or more of
\ its. xiv"* w/ /V°
for the rest of the calendar
EPA Region 2 10
-------
Exhibit IX-10
EPA ID Number & Notification
LQHUW only are required to send a written
notification to EPA of their universal waste
handling activities and obtain an EPA ID
number by calling 212-637-4106
This must be done before meeting or
^r ^^^ ^^m ^^^^3^^^-^E^ B f w ^^^B \ ^^^^ •
exceeding the 5,000 kg storage limit
EPA Region 2 11
-------
Exhibit IX-11
Notification includes:
Statement indicating that the facility is a LQHUW
Name, physical and mailing address of facility
Name and business phone number of person
responsible for managing universal waste at facility
List of all types and quantities of universal waste
managed by the facility (e.g. batteries, pesticides,
thermostats, lamps) "
J( m '
EPA Region 2 12
-------
Exhibit IX-12
Proper Management
All handlers of universal waste must manage
them in a way that prevents releases of the
universal waste or component of universal
waste to the environment
All handlers of universal waste must mark or
label the universal waste to identify the type
of universal waste (e.g., universal waste-
batteries)
EPA Region 2 13
-------
Exhibit IX-13
Labeling
Universal Waste - Battery(ies); or Waste Battery(ies);
or Used Battery(ies).
Universal Waste-Pesticides; or Waste Pesticides.
Universal Waste- Mercury Thermostat(s); or Waste
Mercury Thermostat(s), or Used Mercury
Thermostat(s).
Universal Waste-Lamp(s); or Waste lamp(s); or Used
lamp(s).
EPA Region 2 14
-------
Exhibit IX-14
26 11:23'AH
EPA Region 2
15
-------
Exhibit IX-15
EPA Region 2
16
-------
Exhibit IX-16
EPA Region 2
17
-------
Exhibit IX-17
EPA Region 2
18
-------
Exhibit IX-18
EPA Region 2
19
-------
Exhibit IX-19
1
EPA Region 2
20
-------
Exhibit IX-20
EPA Region 2
21
-------
Exhibit IX-21
EPA Region 2
22
-------
Exhibit IX-22
EPA Region 2
23
-------
Exhibit IX-23
[s&j
EPA Region 2
24
-------
Exhibit IX-24
EPA Region 2
25
-------
Exhibit IX-25
EPA Region 2
26
-------
Exhibit IX-26
EPA Region 2
27
-------
Accumulation Time Limits
Exhibit IX-27
All handlers of universal waste can only keep the universal
waste on-site for a year unless they can prove that a longer
period is necessary to accumulate enough universal waste to
facilitate proper recovery, treatment or disposal
All handlers of universal waste need to be able to demonstrate
the length of time that the universal waste has been
accumulated
EPA Region 2 28
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Exhibit IX-28
Accumulation Time Limits
Labeling a container of universal waste with the
earliest date that any universal waste in the container
became a waste;
Labeling each individual waste with the date it
became a waste;
Maintaining an inventory system on-site that identifies
the date each universal waste became a waste;
EPA Region 2 29
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Exhibit IX-29
Accumulation Time Limits
Maintaining an inventory on-site that identifies the
earliest date that any universal waste items or a
group of containers of universal waste became a
waste;
Placing the universal waste in a specific
accumulation area and identifying the earliest date
that any universal waste in the area became a waste,
EPA Region 2 30
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Exhibit IX-30
Training
SQHUW must train all employees who handle
universal waste about the proper handling and
emergency procedures appropriate to the types of
universal waste handled at the facility
w .^^^fc.
LQHUW must ensure that all employees are
thoroughly familiar with proper waste handling and
emergency procedures relative to their
responsibilities during normal facility operations
and emergencies
EPA Region 2 31
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Exhibit IX-31
Emergency Response
All handlers of universal waste must immediately
contain all releases of universal waste and other
residues from universal waste.
They must also determine if any material resulting
•^^^ ^P^^. \ i m ^^^"^^^^^^^
from the release is a hazardous waste and properly
handle it as such.
EPA Region 2 32
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Exhibit IX-32
Treatment
All universal waste handlers are prohibited from
diluting or treating universal waste.
Some exceptions made for batteries and thermostats
and when responding to releases.
EPA Region 2 33
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Exhibit IX-33
Proper Disposal
All universal waste handlers can only send their
universal waste to other universal waste handlers,
a destination facility, or a foreign destination.
• *
All universal waste handlers need to comply with
•^^^ ^P^^. \ i m ^^^"^^^^^^»
applicable DOT shipping requirements in 49 CFR
1
EPA Region 2 34
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Exhibit IX-34
EPA Region 2
35
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Exhibit IX-3 5
•
EPA Region 2
36
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Exhibit IX-36
EPA Region 2
37
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Exhibit IX-37
Recordkeeping
LQHUW only are required to keep records of their
shipments of universal waste and, if applicable, any
universal waste they receive from other handlers.
. *
These records may take the form of a log, invoice,
manifest, bill of lading, or other shipping
A • ^
documen
EPA Region 2 38
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Exhibit IX-3 8
Recordkeeping (con't)
The record of shipment must include the name and
address of the facility to whom you are sending the
universal waste, the quantity of each type of
universal waste sent, and date of shipment
* * ^ ""** SJ
The record of receipt must include the name and
^T\ ^^ ^Bl ** W • Jf+ ™ ^^\lO^
address of the facility sending you universal waste,
the quantity of each type of tw&ersal waste
received, and the date you received the universal
waste.
EPA Region 2 39
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Exhibit IX-3 9
Relevant Federal Regulations
40 CFR Section 273
Subpart A
Subpart B
EPA Region 2
40
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Exhibit IX-40
Other Guidance
Guidance Material on the Universal Waste Rule
and Hospitals
EPA Region 2
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Exhibit V
Delisted Wastes
No hospital wastes have been delisted yet. Keep for reference.
Overheads from Presentations
Relevant Federal Regulatory Citations
RCRA Policy Excerpts
EPA Region 2
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Exhibit V-l
Delisting - Not Hospital Related
• When a listed waste may be removed from regulatory
control
EPA Region 2
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Exhibit V-2
A Listed Waste Remains A Hazardous
Waste Unless: (Not Hospital Related)
• EPA makes a decision to remove the waste from the list
• A waste is delisted per 40 CFR Sections 260.20 and 260.22
261.3(d)(2)
•In the first case, the process involves a change in the rulemaking:
- EPA determines there is no longer a basis for listing.
- The decision is proposed, comments evaluated, and the decision finalized.
- 40 CFR Part 261 is amended to reflect the removal of the waste from the list.
•In the second case, an applicant petitions EPA to delist a waste for a specific facility/process.
EPA Region 2
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Exhibit V-3
Delisting - Not Hospital Related
• This provision was added to the RCRA regulations because
EPA acknowledges that a particular listed waste from a
particular facility may not be hazardous
•Reasons for delisting include:
- The waste does not contain the constituents or exhibit the characteristics for which it was listed.
- The waste contains constituents at relatively low concentrations.
- The constituents present in the waste are in an immobile form.
- There are no other factors that could cause the waste to be hazardous - this was added by Congress in HSWA because they were concerned that the
Agency was "letting off wastes which should still be included.
•
EPA Region 2
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Exhibit V-4
Delisting Procedures -
Not Hospital Related
• Procedures found in Sections 260.20 and 260.22
• Require the applicant to submit information on
Processes and chemicals used
- Results of tests for hazardous constituents and hazardous waste
characteristics
- Current waste management practices
- Other related information as determined to be necessary by the EPA
• Complex information requirements; regulations supplemented by
guidance documents
• EPA promulgates a delisting in the same manner as it lists - proposal,
public comments, and promulgation
•In many circumstances, the delisted waste is extremely limited in terms of when it was generated, how the waste is to be sampled and analyzed on a
periodic basis, and what constituents are precluded from the delisted waste.
•Delisted wastes are promulgated in Appendix XI of Part 261.
^^^^^^B
EPA Region 2
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Exhibit V-5
Relevant Federal Regulations
40 CFR Part 260
260.20
260.22
40 CFR Part 261
EPA Region 2
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Exercise #1
Waste Codes
EPA Region 2 7
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Exhibit VI
'Mixture" and "Derived-From" Rules
fif
iVV J I I
Overheads from Presentations
Relevant Federal Regulatory Citations
RCRA Policy Excerpts
/ \
EPA Region 2
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Exhibit VI-1
Mixtures
A solid waste is a hazardous waste if:
• It is a mixture of a solid waste and a hazardous waste that is
listed solely because it exhibits a characteristic and the
mixture continues to exhibit characteristics
§261.3(a)(2)(iii)
•This mixture rule was developed to ensure that once wastes are deemed hazardous, and regulated as such, any mixture of the regulated waste and other
wastes should also be considered regulated. The purpose was to provide the incentive to reduce the amount of waste considered hazardous (that is to keep
nonhazardous wastes from being combined with regulated hazardous waste). In addition, for listed waste, EPA wanted to clarify that they are considered
regulated even when mixed.
•However, there are several variations regarding listed wastes. This first provision is a logical follow-on to the derived from rule. If a waste mixture
continues to exhibit a characteristic, the waste should be - and is - considered a regulated hazardous waste. If it does NOT exhibit characteristics, then
the mixture would NOT be regulated hazardous wastes.
^^^^^^^H
EPA Region 2
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Exhibit VI-2
Mixtures (Cont'd)
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
,/
I T
§261.3(a)(2)(iv)
•In the second instance, the mixture is considered hazardous waste. The waste code for the mixture is the waste code of the hazardous waste(s).
EPA Region 2
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Exhibit VI-3
Mixtures (Cont'd)
A solid waste is not hazardous waste if:
• It is a mixture of solid waste and characteristic hazardous
waste and the mixture no longer exhibits any characteristic
• It is a mixture of solid waste and listed hazardous waste
which has been excluded under §260.20 and §260.22
§261.3(a)(2)(iii)and(iv)
•The converse of the mixture rule also applies. Therefore, for characteristic wastes, if the waste no longer meets a characteristic it shouldn't be considered
hazardous. This is the situation where "The solution to pollution is dilution."
•The second instance is if the hazardous waste is delisted, there is no reason for a mixture of the delisted waste and solid waste to be managed as a
hazardous waste.
•LDR has some impermissible dilutions.
EPA Region 2
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Exhibit VI-4
Exceptions (Cont'd)
A mixture is not hazardous waste if it consists of wastewater that is
regulated under Sections 402 or 307(b) of the Clean Water Act and any
of the following hazardous wastes:
Spent carbon tetrachloride, tetrachloroethylene, and/or
trichloroethylene (total weekly usage discharged/average weekly
wastewater flow < 1 ppm)
Spent methylene chloride, 1,1,1-trichloroethane, chlorobenzene,
o-dichlorobenzene, cresols, cresylic acid, nitrobenzene, toluene,
methyl ethyl ketone, carbon disulfide, isobutanol, pyridine,
chlorofluorocarbon solvents (total weekly usage discharge/average
weekly wastewater flow <25 ppm)
§261.3(a)(2)(iv)(A)and(B)
•This general exception of mixtures of wastewater and certain hazardous wastes was promulgated to alleviate the burden to every wastewater treatment
system from being regulated under RCRA. Since they are already regulated under the Clean Water Act, EPA felt this defacto regulation to be
unwarranted. The wastewaters MUST meet the conditions in order to qualify for the exception.
EPA Region 2
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Exhibit VI-5
Exceptions
• Wastewater Mixtures (Cont'd)
- Heat exchanger bundle cleaning sludge (K050)
- Minor spills or leaks of discarded commercial chemical
product or listed chemical intermediate - "de minimis"
losses | V.I J I I
- Wastewater from laboratory operations containing toxic
listed wastes (annualized average flow of laboratory
wastewater < 1% total wastewater flow, or wastes
combined annualized average concentration < 1 ppm
total wastewater flow)
§261.3(a)(2)(iv)(C),(D)and(E)
EPA Region 2 6
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Exhibit VI-6
Derived-From Rule
Residue derived from the treatment, storage, or disposal
of a listed hazardous waste is a hazardous waste unless the residue
has been delisted or the hazardous waste was listed solely for a
characteristic and no longer exhibits a characteristic
11 Y I i
§261.3(c)(2)(ii)
•Logically, if a waste derived from treatment, storage or disposal of a characteristic hazardous waste continues to exhibit any characteristic the derived-from
waste should still be regulated as a hazardous waste.
EPA Region 2
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Exhibit VI-7
Hospital Example of Mixed and
"Derived From" Wastes
If you neutralize acid solutions by mixing them
with alkaline wastes, they are no longer
considered hazardous waste, because the
corrosive characteristic has been removed
§261.3(a)(2)(iii) - (iv) and 261.3(c)(2)(i)
•On May 16, 2001, EPA expanded the mixture rule exclusions with the Hazardous Waste Identification Rule (FR 27266) which allows all wastes listed solely
for characteristics be treated the same. All mixtures, treatment residues, or wastes that do not exhibit ICR characteristics can now exit Subtitle C of RCRA.
Land disposal restrictions may still apply.
EPA Region 2
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Exhibit VI-8
Contained-In Regulatory Interpretation
Used for classification of environmental media (soils,
ground water, sediment) contaminated with listed wastes
Mixture rule does not apply
-W
Derived-from rule does not apply /
Does not affect hospitals unless soil, groundwater, or
sediment remediation is taking place at the hospital
§261.3(d)(2)
•In-place environmental media are not considered solid wastes in the sense of being abandoned, recycled, or inherently waste-like.
•At the time of mixing with listed wastes (i.e., while the soil or ground water is in the subsurface) the environmental media are not solid wastes, and thus
the mixture and derived-from rales do not apply.
•See OSWER Directive 9481.00-6, November 13, 1986 and letter to Thomas C. Jorling, June 19, 1989.
•Under 40 CFR 261.3(g), contaminated media can be eligible for exclusion when it no longer exhibits a characteristic; however, LDR requirements still
apply.
EPA Region 2
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Exhibit VI-9
Contained-In Regulatory Interpretation
(Cont'd)
• Contaminated media must be managed as hazardous waste
because it "contains" listed hazardous waste §261.3(d)(2)
i I ^^
Management of contaminated media as hazardous waste may
cease once hazardous constituents are removed
§261.3(d)(2)
•The level at which a material no longer contains a listed waste is determined by the EPA Regional Offices or Authorized States.
•The future "de minimis" rule, when finalized, will provide regulatory levels below which contaminated media need not be managed as hazardous waste.
EPA Region 2 10
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Exhibit VI-10
Identification of Listed Wastes
• All applicable listings must be included when identifying
mixtures, derived-from wastes, and contained-in wastes (on
manifests, permit applications, etc.)
"K""""™-^.
• For example, if you mix methanol (D001) with picric acid
(D003), you should label the mixture as D001 and D003
•See discussion on 53 FR 31148-49 (August 17, 1988, first third land disposal restrictions rule).
•The F039 listing for hazardous waste leachates was promulgated to alleviate the difficulties presented by identification of leachates which may be
derived-from hundreds of listed hazardous wastes.
EPA Region 2
11
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Exhibit VI-11
Relevant Federal Regulations
Mixture Rule: 40 CFR Part 261
Subpart A 261.3 (a) (2) (Hi)
261.3 (a) (2) (iv)
261.3(d)(2) f
"Derived From " Rule: 40 CFR Part 260
Subpart C 260.20
260.22
\
"Derived From " Rule: 40 CFR Part 261
Subpart A 261.3(d)(2)
EPA Region 2 12
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Exhibit VII
Hazardous Waste Characteristics
.000
Overheads from Presentations
Relevant Federal Regulatory Citations
RCRA Policy Excerpts ^^BSSSS^
EPA Region 2
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Exhibit VII-1
\D002X
A solid waste may be a regulated
hazardous waste if it is either:
Listed
||f or ^v
Characteristic
EPA Region 2
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Exhibit VII-2
Does The Waste Exhibit A
Characteristic?
• A solid waste is a hazardous waste (unless excluded) if it
exhibits any of the characteristics of hazardous waste
- Ignitability
- Corrosivity
s rccMVs.t iv c.
- Reactivity / \ ^fL
- Toxicity \^P^^/ ^56
•The characteristics of hazardous waste are set forth in Subpart C of Part 261.
•Under §261.20(b), a waste must be identified using all applicable EPA hazardous waste numbers. This means that for non-listed wastes, all applicable
characteristic numbers must be used. For listed wastes, all applicable characteristic numbers must be used in addition to the listed waste number for
purposes of compliance with the land disposal restrictions.
EPA Region 2
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Exhibit VII-3
Characteristic of Ignitability
A solid waste exhibits the characteristic of ignitability if
• It is a liquid and has a flash point less than 60°C (140°F)
(aqueous solutions containing less than 24% alcohol are
excluded) ^^(•HRllr
•EPA's objective in developing the ignitability characteristic was to identify wastes capable of causing fires through routine transportation, storage and
disposal, and wastes capable of seriously exacerbating a fire once started (45 FR 33108).
•The term 'liquid' is not specifically defined in the regulation. There are three methods that the Agency has used to determine whether a material is a
liquid: SW-846, Method 9095 (the Paint Filter Test), Step 2 of Method 1310 (the separation step of the Extraction Procedure), and Method 9096 (the
Liquid Release Test). The generator may use any method to make this determination for which he or she can provide an appropriate scientific or
technical justification (55 FR 22543).
•Ignitable liquid wastes include solvents, paint thinners, contaminated oils, and various organic hydrocarbons.
•The Paint Filter Test is commonly used to make the determination of whether a waste is liquid because it is a relatively simple test. A lOOg or 100ml
representative sample of the waste is placed in a Number 60 mesh (fine mesh) conical paint filter for a test period of five minutes. If any of the waste
drops through the filter, the material is determined to be a liquid.
•The flash point determination is made using either of two tests which are specified in the regulation (or by an equivalent test approved by the
Administrator under §260.20 and §260.21):
1. ASTM Standard D-93-79 or D-93-80 using a Pensky-Martens Closed Cup Tester; or
2. ASTM Standard D-3278-78 using a Setaflash Closed Cup Tester.
•The exclusion for aqueous liquids containing less than 24% alcohol was intended to avoid regulation of wastes such as wine and some latex paints which
have low flashpoints due to alcohol content but do not sustain combustion because of high water content. However, since the general term 'alcohol' was
used rather than 'ethanol', the exclusion applies to any type of alcohol or combination of alcohols (55 FR 22543). The term 'aqueous' is interpreted to
mean a liquid that contains at least 50% water by weight (OSWER Directive 9443.02).
EPA Region 2
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Exhibit VII-4
Characteristic of Ignitability (Cont'd)
A solid waste exhibits the characteristic of ignitability if
(cont'd): j^
• It is not a liquid and is capable of causing fire through
friction, absorption of moisture or spontaneous chemical
changes and when ignited burns so vigorously and
persistently that it creates a hazard
§261.21
•There are no test methods or quantitative criteria specified for the determination of whether a solid is ignitable.
•A waste must meet two criteria to be considered ignitable under this provision: the material must both be unstable such that it is capable of causing fires
through friction, absorption of moisture or chemical change and it must continue to burn vigorously and persistently after ignition so as to create a hazard.
•Known as Reactive Ignitables, this category primarily includes inorganic solids and wastes containing reactive materials.
•Examples of Reactive Ignitables that are reactive with water and generate gases that can ignite and burn include:
- Reactive alkali metals or metaloids such as sodium and potassium.
- Calcium carbide slags.
•Metals such as magnesium and aluminum, which in the dust or powdered form, can vigorously react with oxygen and cause fires.
EPA Region 2
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Exhibit VII-5
Characteristic of Ignitability (Cont'd)
A solid waste exhibits the characteristic of ignitability if
(cont'd): ySPpfcv
• It is an ignitable compressed gas
• It is an oxidizer
§261.21
•The term compressed gas is defined in 49 CFR 173.300 (DOT) and includes:
- Materials having in the container an absolute pressure > 40 psi at 21°C (70°F); or
- Materials having an absolute pressure > 104 psi at 54°C (130°F) (regardless of the container); or
- Liquid flammable materials having a vapor pressure > 40 psi at 38°C (100°F).
•A compressed gas is considered ignitable if:
- At atmospheric temperature and pressure, a mixture of 13% or less with air forms a flammable mixture or the flammable range with air is wider than
12%, regardless of the lower limit, using sampling and testing methods acceptable to the Bureau of Explosives; or
- The material fails specified tests using the Bureau of Explosives' Flame Projection Apparatus or Closed Drum Apparatus.
•The term oxidizer is defined in 49 CFR 173.151 (DOT) as any material that yields oxygen readily to stimulate the combustion of organic matter. Several
examples are listed including chlorate, permanganate, inorganic peroxide, and metallic nitrates.
EPA Region 2
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Exhibit VII-6
Hospital Examples of Wastes
Exhibiting Ignitability
Rubbing Alcohol (liquids with > 24% alcohol)
Paregoric
Methanol
Topical Preparations
Injections
Some Cough Medicines
Nyquil ®
EPA Region 2
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Exhibit VII-7
Hospital Examples of Wastes
Exhibiting Ignitability (Cont'd)
• Cleocin T Topical Solution
• Retin A Gel J^K^^^
• Erythromycin Topical Solution
• Collodion Based Preparations
• Silver Nitrate
• Certain mouthwashes (Listerine® has >24% alcohol)*
*Source for Listerine® content: http://www.addictionend.conVbookonline/34.htm
EPA Region 2 8
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Exhibit VII-8
Hospital Examples of Wastes
Exhibiting Ignitability (Cont'd)
• Ammonia Inhalants
• Amyl Nitrate
• Anbesol ® Pli *m
Aquanet ® Aerosol Spray
Benoxyl Peroxide
Benzoin Tincture
*Source for Listerine® content: http://www.addictionend.conVbookonline/34.htm
EPA Region 2
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Exhibit VII-9
Hospital Examples of Wastes
Exhibiting Ignitability (Cont'd)
• Bronchial Dilators
• Compound W ® j^m*^.
• Merthiolate Tincture ^BVd '^Rr
^•^Hp ^^1
• Peppermint Spirit
• RightGuard ® Aerosol Spray
• Solarcaine ® Aerosol Spray
*Source for Listerine® content: http://www.addictionend.conVbookonline/34.htm
EPA Region 2 10
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Exhibit VII-10
Characteristic of Corrosivity
A solid waste exhibits the characteristic of corrosivity if:
• It is aqueous and has a pH of <2 or >12.5
§261.22
•EPA's objective in developing the corrosivity characteristic was to identify wastes capable of:
- Mobilizing toxic constituents from other wastes (particularly metals),
- Reacting dangerously with other wastes,
- Corroding storage or transportation vessels and equipment, and
- Damaging human or animal tissue in the event of inadvertent contact.
•The term aqueous is interpreted to mean a liquid that contains at least 50% water by weight (OSWER Directive 9443.02).
•To determine whether an aqueous waste is corrosive, the pH is determined using a pH meter as described in SW-846 Method 9040 (also described in "Methods
for Analysis of Water and Wastes" EPA 600/4-79-020) or an equivalent test method approved by the Administrator under §260.20 and §260.21.
EPA Region 2
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Exhibit VII-11
Characteristic of Corrosivity (Cont'd)
A solid waste exhibits the characteristic of corrosivity if
(cont'd):
It is a liquid and corrodes steel at a rate > 6.35 mm (0.25 in)
per year at a temperature of 55°C (130°F)
DOO;
§261.22
•The determination of whether a liquid corrodes steel at a rate > 6.35 mm is made using the National Association of Corrosion Engineers (NACE).
Standard TM-01-60 as standardized in SW-846 Method 1110 or an equivalent test method approved by the Administrator under §260.20 and §260.21.
•Method 1110 requires that coupons of SAE Type 1020 steel be immersed in a representative sample of the waste at 55°C for approximately 24 hours.
The rate of corrosion is calculated as: ,..., ~ , , \\/ii AI-\
^ _ . . (initial mass-final mass (mg))( 11.45)
Corrosion Rate (mm/y) = -
(exposed area (cm ))(time (h))
•The term liquid, as in the ignitability characteristic, is not specifically defined.
•Non-liquids cannot, by definition, be corrosive hazardous wastes.
•Common examples of corrosive wastes include:
- acetic acid - nitric acid
- chromic acid - oleum
- hydrobromic acid - perchloric acid
- hydrochloric acid - phosphoric acid
- hydrofluoric acid
- sulfuric acid
- ammonium hydroxide
- potassium hydroxide
- sodium hydroxide
EPA Region 2
12
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Exhibit VII-12
Examples of Hospital Wastes
Exhibiting Corrosivity
• Glacial acetic acid with pH less than or equal to 2
Sodium hydroxide with pH greater than or equal to 12.5
Liquid Phenol (Carbo
Potassium Hydroxide
EPA Region 2
13
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Exhibit VII-13
Characteristic of Reactivity
A solid waste exhibits the characteristic of reactivity if:
It is normally unstable and readily undergoes violent change
without detonation ^ ^J/
It reacts violently with water
It forms potentially explosive mixtures with water
§261.23
•EPA's objective in developing the reactivity characteristic was to identify wastes that because of their extreme instability and tendency to react violently
or explode, pose a problem at all stages of the waste management process.
•There are few test methods or quantitative criteria specified for the determination of whether a waste is reactive.
•The reactive waste definition is to a large extent a paraphrase of the National Fire Protection Association's (NFPA) narrative definition - because it was
determined that the available tests for these properties suffered from a number of deficiencies.
EPA Region 2 14
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Exhibit VII-14
Characteristic of Reactivity (Cont'd)
A solid waste exhibits the characteristic of reactivity if
(cont'd):
/>
T+ f
It generates toxic gases, vapors, or fumes in dangerous
quantities when mixed with water ^
• It is a cyanide- or sulfide-bearing waste which, when
exposed to pH conditions between 2 and 12.5, can generate
toxic gases, vapors, or fumes in dangerous quantities
§261.23
•The Agency developed guidance for determining whether a cyanide- or sulfide-bearing waste is reactive but remanded it in 1998. Wastes with high
concentrations of cyanide and sulfide should be considered hazardous waste based on the narrative standard.
EPA Region 2 15
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Exhibit VII-15
Characteristic of Reactivity (Cont'd)
A solid waste exhibits the characteristic of reactivity if
(cont'd):
It is capable of detonation or explosive reaction if subjected
to strong initiating sources or if heated under confinement
• It is readily capable of detonation, explosive decomposition,
or reaction at standard temperature and pressure (STP)
• It is a Forbidden, Class A, or Class B Explosive
•Forbidden explosive is defined in 49 CFR 173.51 (DOT) and includes nitroglycerine, diethylene glycol dinitrate, loaded firearms, leaking or damaged
packages of explosives, specific fireworks, specific explosive mixtures and devices, and materials that ignite spontaneously or undergo marked
decomposition when subjected to a temperature of 75°C (167°F) for 48 hours.
•Class A and Class B explosives are defined in 49 CFR 173.53 and 173.88, respectively.
•Common reactive wastes include:
- acetyl chloride - hypochlorites - permanganates
- chromic acid - organic peroxides - oxidizers
- cyanides - perchlorates
^^^^^^^H
EPA Region 2 16
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Exhibit VII-16
Examples of Hospital Wastes
Exhibiting Reactivity
Lithium- sulfur batteries
Picric acid (dry)
Nitroglycerin formulations
• Clinatest
EPA Region 2
17
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Exhibit VII-17
Picric Acid
2,4,6-trinitrophenol, picronitric acid, melinite
Sometimes used in histology labs
A component of Bouin's Solution- tissue
preservative ^Mfl
Dry picric acid is explosive and disposal is very
costly and disruptive
isruptive
(\—Lt
N-XXWw^
EPA Region 2
18
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Exhibit VII-18
Picric Acid (Cont'd)
EPA Region 2
19
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Exhibit VII-19
EPA Region 2
20
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Exhibit VII-20
EPA Region 2
21
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Exhibit VII-21
Ethylene Oxide - EtO
Used to sterilize surgical equipment.
Very low flashpoint ~4F
Wide explosive range
Severe explosion hazard when exposed to heat or
flame 1^^
rr /
Incompatible with many materials
EPA Region 2 22
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Exhibit VII-22
EPA Hazardous Waste Codes
Ignitable Wastes - D001
Corrosive Wastes - D002
I ^
Reactive Wastes - D003
2TIVE >w
\
\
\7
•Wastes exhibiting the characteristics of ignitability, corrosivity, and reactivity are assigned all of the appropriate EPA Hazardous Waste Code as identified
above.
EPA Region 2
23
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Exhibit VII-23
Toxicity Characteristic
A solid waste exhibits the characteristic of toxicity if:
• The Toxicity Characteristic Leaching Procedure (TCLP)
defines it as toxic j^fJTO^v
• The TCLP measures how much contamination would drain
(leach) from waste and pollute groundwater
EPA Region 2 24
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Exhibit VII-24
Examples of Hospital Wastes
Exhibiting Toxicity
• Chloroform
Lindane
m-Cresol ^^isuiw
Mercury and Mercury Compounds (Thimerosal)
Phenylmercuric Acetate
Arsenic Compounds
Barium Compounds
Certain other metal compounds (e.g., chromium, cadmium,
selenium, silver)
EPA Region 2 25
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Exhibit VII-25
Examples of Hospital Wastes
Exhibiting Toxicity
Fluogen
Fluzone
Insulin with Cresol
Merbromin
^a
EPA Region 2
26
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Exhibit VII-26
TC Wastes
Chemical
Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
Concentration
(mg/l )
^^^^^^^^^^^^^^^^^^^^^
100.0
1.0
^ 5.0
Waste Code
D005
D006
D007
EPA Region 2
27
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Exhibit VII-27
TC Wastes (Cont'd)
Chemical
Benzene
Selenium
Silver
Lindane
Benzene
Carbon
Tetrachloride
Concentration
(mg/l )
0.5
1.0
^5 5.0
^ 0.4
0.5
Waste Code
D010
D011
D013
D019
EPA Region 2
28
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Exhibit VII-28
TC Wastes (Cont'd)
Chemical
Chlorobenzene
Chloroform
o-Cresol
m-Cresol
p-Cresol
Cresol
Concentration
(mg/l )
100.0
6.0
200.0
200.0
Waste Code
D021
D022
D025
EPA Region 2
29
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Exhibit VII-29
TC Wastes (Cont'd)
Chemical
1 ,4-Dichlorobenzene
Hexachloroethane
Methyl Ethyl Ketone
Nitrobenzene
Pyridine
Tetrachloroethylene
Concentration
(mg/l )
7.5
3.0
200.0
2.0
5.0
Waste Code
D027
D034
D036
D038
EPA Region 2
30
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Exhibit VII-30
TC Wastes (Cont'd)
Chemical
Trichloroethylene
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
Concentration
(mg/l )
0.5
400.0
2.0
Waste Code
D040
D041
EPA Region 2
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Exhibit VII-31
Waste Codes
A simple way to remember waste
codes
FKD UP
EPA Region 2
32
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Exhibit VII-32
Mercury-Containing Devices &
Products
In Patient Rooms
• Temperature Measurement
Blood Pressure
Nursing Incubators
Room Temperature Controller*
Batteries
EPA Region 2 33
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Exhibit VII-3 3
Mercury-Containing Devices &
Products (Cont'd)
In Storage and Maintenance Rooms
• Antifouling agents
f"
* Cleaning Chemicals
Degreasers
• Preservatives
• Solvents
• Outdated mercury-containing equipment
• Paints
EPA Region 2 34
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Exhibit VII-34
Mercury-Containing Devices &
Products (Cont'd)
In Treatment and Surgery Rooms
• Merthiolate
i
• Mercury Nitrate
I
Mercury Iodide
Mercurochrome
Thimerosal
EPA Region 2
35
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Exhibit VII-3 5
Mercury-Containing Devices &
Products (Cont'd)
In Treatment and Surgery Rooms (contM)
• Esophageal
• Cantor Tubes
Miller Abbot Tubes
Feeding Tubes
Dental Amalgam
EPA Region 2
36
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Exhibit VII-3 6
Waste Identification
• Generators are responsible for determining whether wastes are
hazardous >^HI^^^v /^ORROSIV^
• If waste is not excluded, the generator must determine whether
the waste is listed or exhibits any hazardous waste characteristics
• Determination may be based on testing or knowledge
• If waste is hazardous and subject to Subtitle C control, generator
must keep records unless the waste is specifically excluded or
managed in exempt units
§262.11
•Under TC, generators remain responsible for determining whether waste is hazardous.
- Generators are not required to test wastes to make this determination.
- If a waste is excluded from regulation (40 CFR 261.4) or is listed (Subpart D of 40 CFR Part 261), no further determination of hazardousness is necessary.
•If waste is not excluded, the generator must determine whether the waste exhibits any hazardous waste characteristics, TC being one such characteristic.
- Generator may determine whether waste exhibits a characteristic by (a) testing the waste or (b) applying knowledge of the waste.
•If a waste is hazardous, the generator must keep records.
- Records establishing basis for waste identification determination must be kept at least three years after generator handles the waste.
EPA Region 2 37
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Exhibit VII-3 7
..
Relevant Federal Regulations
40 CFR Part 261
261.20 - 261.24
-
EPA Region 2
38
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Exhibit VIII
Recycled Materials
Overheads from Presentations
Relevant Federal Regulatory Citations
RCRA Policy Excerpts
EPA Region 2
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Exhibit VIII-1
Recycling
Definition
Certain materials are not subject to regulation when
recycled
Nature of material
Manner of recycling
Determination of regulatii
Materials that are not solid waste when recycled
Certain recycled materials are regulated under Part 266
EPA Region 2
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Exhibit VIII-2
The Regulations Governing Materials
That Are Recycled
• Exclude some recycled materials from the definition of solid
waste
• Specify the applicable regulations for the management of
recycled wastes (recyclabl
§261.2,261.6
•Decision Diagram B is used to determine which recycled materials are not solid wastes and which regulations apply to various types of recycled wastes
and recycling activities.
•The regulations governing hazardous waste recycling activities include:
- Standard Subtitle C regulation of generation, transportation, and storage (the recycling activity itself is exempt from 264/265 regulation except for the
air emissions standards of Subparts AA and BB) (§261.6(a)(l));
- Part 266 recycling regulations for specific recycling operations (§261.6(a)(2)); or
- Exemption from standard Subtitle C regulation (§261.6(a)(3)).
•The frame work for the recycling regulations was formulated on January 4, 1985 (50 FR 614).
EPA Region 2
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Exhibit VIII-3
Recycle: A General Definition
A material is recycled if
it is used, reused or reclaimed
§261.1(c)(7)
•"Reclaimed" is defined in §261.1(c)(4).
•"Used or reused" is defined §261.1(c)(5).
•Materials are also recycled if they are (§261.2(c)):
- Used in a manner constituting disposal;
- Burned for energy recovery or used as a fuel; or
- Speculatively accumulated
(these terms are discussed in detail - on following pages).
EPA Region 2
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Exhibit VIII-4
Certain Materials Are Not Subject To
Regulation When Recycled
• Industrial ethyl alcohol that is reclaimed
• Used batteries returned for regeneration
Used oil exhibiting any ofJB^^^acteristics of hazardous
waste that is recycled in a manner other than burning for
•/ ^^
energy recovery
§261.6(a)(3)
•These materials are solid waste, and if listed or exhibit characteristics, are hazardous waste. They are, however, not subject to the hazardous waste
regulations.
•Redistillation of industrial ethyl alcohol is regulated by the Bureau of Alcohol, Tobacco and Firearms.
•Used batteries that are recycled (i.e., the casing is cracked) are not included in this exemption.
•Used oil that is refined (and also exhibits a characteristic) is not subject to the hazardous waste regulations.
EPA Region 2
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Exhibit VIII-5
Certain Materials Are Not Subject To
Regulation When Recycled (Cont'd) -
Not Hospital Related
• Scrap metal
• A variety of reclaimed oils and oil-derived fuels associated
•>
with oil refining
car
• Coke and coal tars containing hazardous wastes from iron
and steel production process^(K087)
§261.2(a)(3)
•For further information on the petroleum refining and coke and coal tar wastes see 50 FR 49204 (the original burning and blending regulations).
EPA Region 2
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Exhibit VIII-6
In general, determination of whether a recycled
material is a solid waste depends upon the NATURE
of the material and the MANNER in which it is recycled
§261.6(a)(3)
•Recycled materials determined not to be solid wastes cannot, by definition, be hazardous wastes and thus are not subject to the hazardous waste
regulations.
EPA Region 2
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Exhibit VIII-7
Nature of Recycled Materials
• For purposes of determining if a recycled material is a solid
waste when recycled, five classes of materials are
considered
- Spent materials
- Sludges
- By-products
- Commercial chemical products
rVM/
- Scrap metal *!?
§261.2
•All recycled material fit into one of these classes.
•Each class of materials will be discussed in detail.
EPA Region 2
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Exhibit VIII-8
Spent Materials
Any material that has been used and, as a result of contamination,
can no longer serve its intended purpose without reprocessing
- Spent solvents
- Spent catalysts
- Spent pickle liquor
Spent plating bath solutions
Hospital Examples:
• Used Bouin's solution
• Spent laboratory solvent
§26U(c)(l)
•Listed spent material include: F001-F005, F007, F009, F011, K021, K028, K045, K062, K088, Kl 18.
•Materials that can continue to be used for the purposes for which they were produced (e.g., a slightly contaminated solvent that can be used for
degreasing) are not spent materials.
EPA Region 2
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Exhibit VIII-9
Sludge - Not Hospital Related
• Residues from pollution control devices
- Wastewater treatment plant sludges
- Electric arc furnace dust (K061)
- Baghouse dusts
§261.10
•The term sludge is defined in §260.10 as "any solid, semi-solid, or liquid waste generated from municipal, commercial, or industrial wastewater treatment
plant, or air pollution control facility, exclusive of the treated effluent from a wastewater treatment plant."
•Listed wastewater treatment sludges include F006, F012, F019, K001, K002-K007, K032, K035, K037, K040, K041, K044, K046, K048, K051, K106.
•Listed air pollution control sludges include K061, K069, K090, K091.
EPA Region 2 10
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Exhibit VIII-10
By-Products - Not Hospital Related
• Process residues that are not one of the primary products of
a production process
- Distillation column bottoms
- Heavy ends
- Slag
§26U(c)(3)
•The term by-product is defined in §261.1(c)(3) as "a material that is not one of the primary products of a production process and is not solely or separately
produced by the production process."
•By-products must be distinguished from co-products.
EPA Region 2 11
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Exhibit VIII-11
Co-Product (Not A Nature Of Recycled
Materials) - Not Hospital Related
• A material intentionally produced by the manufacturing
process and ordinarily used igjts existing state as a
commodity in trade by the ggfeltl public
Co-products must have a recognized use, and must be
usable without reprocessing
§261.1(c)(3)
•Examples of co-products:
- Acetone produced when phenol is manufactured from cumene;
- Kerosene, asphalt, and pitch from petroleum refining; and
- Sulfuric acid produced in acid plants associated with smelters.
•The term co-product is discussed in the §261.1(c)(3) definition of by-product.
•Co-products are generally suitable for use as-is, without substantial reprocessing.
•See discussion on 50 FR 625 (January 4, 1985).
EPA Region 2 12
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Exhibit VIII-12
Commercial Chemical Products
• Based on statutory definition
• Includes all types of unused commercial products whether
or not they would commonly be considered chemicals (e.g.,
circuit boards, thermometers^ batteries, and other types of
equipment and manufactured articles)
-^- -^- ffIL *- ^11 I V^^E •*
The compounds listed in §261.33 (P- and U- wastes)
Also includes commercial chemical products that exhibit a
characteristic
•Includes intermediate, off-specification variants, spill residues and container residues.
•Products are generally not wastes, however, when they are recycled in ways that differ from their normal use they may be considered solid wastes .
•Examples:
- Products that are not fertilizers used by 'placement' on the land.
- Products that are not fuels burned for energy recovery.
EPA Region 2 13
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Exhibit VIII-13
Scrap Metal
• Metal pieces and parts which, when worn or superfluous,
can be recycled
• Examples
- Scrap automobiles
- Machine shop turnin
§26U(c)(6)
•Scrap metal includes:
- bits and pieces of metal, and pieces combined with bolts or soldering, and
- metal generated from machinery operations.
•The following are not scrap metal:
- residues from smelting and refining (e.g., drosses, slags).
- liquid wastes containing metal (e.g., spent acids with metals in solution).
- liquid metal wastes (e.g., mercury), and
- metal containing wastes with a significant metal content (e.g., batteries).
EPA Region 2 14
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Exhibit VIII-14
Manner of Recycling
Five methods of recycling to be considered in determining
if a recycled material is a solid waste
- Use in a manner constituting disposal
- Use as a fuel or burning fqj* energy recovery
- Reclamation
- Speculative accumulal
- Use/reuse
§261.2(c)and(e)
•Each method will be discussed in detail.
•All recycling activities fit into one of these categories.
EPA Region 2 15
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Exhibit VIII-15
Use Constituting Disposal -
Not Hospital Related
• The material is applied to or placed on land
• The material is contained in a product applied to the land
(except for commercial chgrgp^^roducts that are normally
placed on the land, e.g.,
§261.2(c)(l)
•Disposal is defined in §260.10.
•Use constituting disposal is discussed in §261.2(c)(l).
•Examples:
- Use as fill or cover,
- Use as a dust suppressant, and
- Use in asphalt or cement placed on land.
•The use of hazardous wastes in a manner constituting disposal is regulated under Subpart C of Part 266.
EPA Region 2 16
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Exhibit VIII-16
Burned For Energy Recovery/Used As
A Fuel - Not Hospital Related
• The material is burned for energy recovery in a boiler or industrial
furnace
The material is used to produce a fuel
The material is contained in ~ ^^™
§261.2(c)
•Burning for energy recovery is regulated under Part 266, Subpart H (hazardous waste) and Subpart E (used oil).
•Any burning other than for energy recovery or for material recovery (reclamation) or as an ingredient is defined as incineration, which is a form of treatment.
not recycling. Incineration is regulated under Subpart O of Parts 264 and 265.
•The term 'boiler' is defined in §260.10 as a unit having physical provisions for recovering and exporting thermal energy in the form of steam, heated fluids, or
heated gases. The combustion chamber and primary energy recovery sections of these units must be of integral design, the unit must have a thermal energy
recovery efficiency greater than 60% and, on an annual basis, 75% of the recovery sections of these units must be of integral design, the unit must have a
thermal energy determine that individual units are boilers, on a case-by-case basis, using the criteria set forth in §260.32.
•The term 'industrial furnace' is defined in §260.10 to include:
- Cement, lime, aggregate, and phosphate kilns.
- Coke ovens,
- Blast furnaces,
- Smelting, melting, and refining furnaces,
- TiO2 chloride process oxidation reactors,
- Methane reforming and pulping liquor recovery furnaces.
- Spent sulfuric acid recovery combustion units.
- Halogen acid furnace, and
- Units added to the list by the Administrator based on the criteria in §260.10.
EPA Region 2 17
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Exhibit VIII-17
Reclamation
• Processing to recover a usable product
• Regeneration
§261.2(c)(4)
•Reclamation is defined in §261.1(c)(4).
•Wastes are processed to recover usable product when distinct components of the material that are of value are recovered (e.g., recovery of metals from
electroplating wastewater treatment sludges (F006)).
•Wastes are regenerated when they are processed to remove contaminants in a way that restores them to their usable original condition (e.g., distillation of
spent solvents).
EPA Region 2
18
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Exhibit VIII-18
Speculative Accumulation
Speculative accumulation is defined as the accumulation of waste
materials prior to recycling without sufficient amounts being recycled
Sufficient amount is defined as at least 75% during a calendar year
EPA may grant a variance on a case-by-case basis for materials that are
accumulated speculatively (<
Hospital Examples:
• Stockpiled electronics
• Excess materials that are no longer needed or used at facility
(e.g., old paints and cleaning supplies) that are listed or exhibit
a characteristic
• Unused Pharmaceuticals that are not returned to manufacturer
that are listed or exhibit a characteristic
§261.1(c)(8)
•75% is calculated on an annual (January 1 to January 1) basis.
•The speculative accumulation provisions are only relevant for materials generally defined not to be solid waste (see chart on following page).
EPA Region 2
19
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Exhibit VIII-19
Use/Reuse
Recyclable materials are not solid wastes when
- Used or reused as ingredients or feedstocks in
production process
- Used or reused as effectiv/e^substitutes for commercial
products
- Returned directly to the original primary production
\ i § ^^"4
process in which they are generated
§261.2(e)(l)
•Use/reuse is defined in §261.1(c)(5).
•Examples:
- Still bottoms from carbon tetrachloride manufacture (KOI6) are used as a feedstock in tetrachloroethylene production.
- Use of spent pickle liquor (KOI6) as a wastewater conditioner.
- Use of fly ash from electric power production as a feedstock in the manufacture of cement.
EPA Region 2
20
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Exhibit VIII-20
Use/Reuse (Cont'd)
Materials must be used, reused, or returned to original
process directly without first being reclaimed
These exclusions do not apply^materials used in a manner
in*//
constituting disposal, burned for energy recovery, or
speculatively accumulated (§261.2(e)(2))
•Exclusion is crafted to distinguish between production processes (over which the Agency does not have authority under RCRA) and waste management
process (over which the Agency does have authority under RCRA).
•Incidental processing is not considered reclamation (e.g., wetting materials to minimize wind dispersal, briquetting of dry wastes, combination of
feedstocks).
EPA Region 2 21
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Exhibit VIII-21
Use/Reuse (Cont'd)
Hospital Example: Cerrobend
• X-Ray shielding putty used to protect patients from
damage to adjacent healthy tissue during irradiation of
tumors and other
• Contains lead and cadmium
^
• Discarded materials and shavings can be characteristic
toxic HW when discarded
• Can be reshaped and reused many times before being
discarded
EPA Region 2 22
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Exhibit VIII-22
When are Recycled Materials
Regulated?
Spent materials
Sludges that are listed
hazardous wastes
Sludges exhibiting a
characteristic of
hazardous waste
By-products that are listed
hazardous wastes
By-products exhibiting a
characteristic of
hazardous waste
Commercial chemical
products
Scrap metal
Use Constituting
Disposal
(261.2(c)(l))
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Energy
Recovery /Fuel
(261.2(c)(2)
Y^§7%
pyp
Yes
Yes
Yes
Reclamation
(261.2(c)(3))
Yes
Yes
No
Yes
No
No
Speculative
Accumulation
(261.2(c)(4))
Yes
Yes
Yes
Yes
Yes
No
Use/Reuse
(261.2(e)(l))
No
No
No
No
No
No
EPA Region 2
23
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Exhibit VIII-23
Certain Recycled Materials Are
Regulated Under Part 266
• Materials used in a manner constituting disposal (Subpart C)
• Used oil burned for energy recovery (Subpart E)
•Subpart C subjects all other materials used in a manner constituting disposal to all applicable hazardous waste regulations (Parts 262-268, 270, 124)
(i.e., interim status or permits and land disposal unit standards.)
•Subpart C exempts products containing recyclable hazardous wastes produced for the general public's use and used in a manner constituting disposal
from the hazardous waste regulations if:
- The hazardous waste has undergone a chemical reaction such that it is inseparable by physical means from the other constituents of the product; and
- The product meets the applicable land disposal restriction of Part 268 (fertilizers containing K061 are not subject to regulation without conditions).
•See discussion on used oil in Exhibit IV, Listed Wastes.
•All used oil burned for energy recovery is regulated under Subpart E. The authority for regulation of used oil that does not exhibit characteristics (i.e., is
not hazardous waste) is the Used Oil Recycling Act of 1980 (Section 3014 of RCRA).
•Used oil burned for energy recovery that has been mixed with listed hazardous wastes is subject to Subpart D (the rebuttable presumption).
EPA Region 2 24
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Exhibit VIII-24
Certain Recycled Materials Are
Regulated Under Part 266 (Cont'd)
• Recyclable materials utilized for precious metals recovery
(Subpart F)
• Spent lead-acid batteries being reclaimed (Subpart G)
*"SfW
Silver recovery from photo and X-Ray processing
§261.6(a)(2)
•Hazardous wastes from which precious metals are reclaimed are subject only to notification, manifesting, and recordkeeping requirements except as
required by §§260.40 and 41.
•Reclamation of spent lead-acid batteries involves cracking the casing (regeneration does not, see §261.6(a)(3)(ii)).
•Generators and transporters of lead-acid batteries that are reclaimed are not subject to the hazardous waste regulations. Reclaimers are subject to Part 264
requirements, excluding manifest and waste analysis provisions, for storage of the batteries prior to reclamation.
EPA Region 2 25
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Exhibit VIII-25
Certain Recycled Materials Are
Regulated Under Part 266 (Cont'd) -
Not Hospital Related
• Hazardous waste burned in boilers and industrial furnaces
(Subpart H)
§261.6(a)(2)
•Subpart H exempts certain hazardous wastes from regulation under this subpart:
- Used oil burned for energy recovery subject to Subpart E,
- Gas recovered from hazardous or solid waste landfills when such gas is burned for energy recovery.
- Hazardous waste exempt from regulations under §2621.4, §261.6(a)(3) (v-viii) and §261.5, and
- Coke ovens if burning K087.
EPA Region 2 26
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Exhibit VIII-26
Regulation of Recycled Materials
• Hazardous wastes prior to reclamation are subject to the full
set of hazardous waste regulations (Parts 262-268, 270, and
124)
The reclamation process itsei&i^exempt from regulation
§261.6(a)(l),(b),and(c)
•Generation, transportation, and storage prior to reclamation are fully regulated.
•By-products from the reclamation process may also be regulated hazardous waste.
•Reclamation processes may be subject to the air emissions control requirements of Parts 264 and 265 if applicable (§261.6(d)).
EPA Region 2 27
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Exhibit VIII-27
On-Going Review Of The Definition
Of Solid Waste
• October 28, 2003: Proposed rule for "Revisions to
Definition of Solid Waste"
• Comment period ended January 26, 2004. Rule is expected
to be finalized 12/06
Proposed rule aims to identify Remain recyclable hazardous
secondary materials as not discarded
• If these materials are exempted from the definition of solid
waste, then the wastes no longer are regulated under
Subtitle C
•Industry challenged EPA's authority under RCRA to regulate certain recycled hazardous materials in court cases in 1987, 1988, and twice in 1990 where
the definition of solid waste was interpreted by the court system.
•The proposed rule will redefine solid waste.
EPA Region 2 28
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Exhibit VIII-28
Relevant Federal Regulations
40 CFR Part 261
SubpartB Section 261.1 (c)
Section 261.2
Section 261.6
40 CFR Part 266
Subpart C
Subpart D
Subpart E
Subpart F
40 CFR Part 273
Subpart A
Subpart B
EPA Region 2 29
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Exercise #2
Mercury
EPA Region 2 30
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Exhibit X
Generator Requirements
Overheads from Presentations
•/
Relevant Federal Regulatory Citations
Other Guidance
RCRA Policy Exa
EPA Region 2
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Exhibit X-l
Three Tiers of Generators
Conditionally-Exempt Small Quantity Generators (CESQGs)
1H a ^VY~n2
Small Quantity Generators
^^ ^^L.
Large Quantity Generators
•In 1980, EPA recognized it could not administer a regulatory program with more than 100,000 in the regulated community.
•Therefore, they used existing information to determine a reasonable "cut-off point for small quantity generators who would be excluded from
regulation. They used the traditional "20-80" concept - 20% of the generators produce 80% of the wastes.
•This resulted in a 1000 kg/mo designation as an SQG. This amounts to about four 55-gallon drums for materials with a density similar to water.
•The preamble to the regulation, however, committed EPA to evaluate the cut-off and revise the regulations as necessary to reflect their findings.
•Under HSWA, Congress mandated the EPA to lower the cut-off.
•In 1985, EPA amended the regulations to establish a three-tiered system for designating generators.
EPA Region 2
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Exhibit X-2
CESQGs
• Produce < or = 100 kg/mo of non-acute hazardous waste
I n n 5R&M»cd*.id
Produce < 1 kg/mo of acute hazardous waste (e.g.,
epinephrine
Produce < 1Offl
or other debris from s
of residue or contaminated soil, waste,
acutely hazardous waste
EPA Region 2
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Exhibit X-3
SQGs
Produce between 100 kg and 1000 kg/mo of non-acute
hazardous wast<
Produce < 1
Produce < 100 kg/mo of residue or
or other debris from s
s waste
ntaminated soil, waste,
acute hazardous waste
EPA Region 2
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Exhibit X-4
LQGs
Produce >= 1000 kg/mo of non-acute hazardous waste
Produce >= 1 kg/mo of acute hazardous waste
Produce >= 100 kg/mo or residue or contaminated soil, waste,
or other debris from spill cleanup of acute hazardous waste
>^^J-—*i *
EPA Region 2
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Exhibit X-5
Regulations
CESQGs regulated under Section 261.5
I H 3 S^
SQGs must meet limited requirements in Part 262
LQGs must meet full set of Pa
equirements
EPA Region 2
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Exhibit X-6
Regulation Status is Determined on a
Month-to-Month Basi
A generator may produce less than 100 kg in January but
greater than
• January - CESQ
• February-
During the LQG months, the full set of Subtitle C rules
applies and facility is subject to applicable annual reporting
requirements for that year
EPA Region 2 7
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Exhibit X-7
Generator Status
Most Hospitals are SQGs
Practices such as remodeling X-ray areas (lead shielding
discarded) or periodic storage room cleanouts can result in
classification as a LQG that month
Pay special attention to acutely hazardous waste - - generating
one kilogram in a month can make you a LQG
EPA Region 2
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Exhibit X-8
Waste Counting
Non-acute Hazardous
universal wastes are
e, acute hazardous waste, and
arately
Samples of solid waste collected for the sole purpose of
testing to determine its characteristics or composition or for
treatability studies are not counted during storage and
transportatioi
rofc^crza^ ^^j
at laboratories and
Samples und
testing facilitie
EPA Region 2
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Exhibit X-9
Waste Counting (continued)
^•^ ^. S
NOTE: Your building/clinic may be part of a larger
facility and subject to regulations based on total
hazardous waste generation.
EPA Region 2
10
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Exhibit X-10
Waste Counting, continued
If a hazardous waste has been included in the quantity
determination one month, do not count it again when
removing it from storage, or count any hazardous waste
derived from on-site treatment of that hazardous waste
Similarly, don'
t spent materials generated, reclaimed
and subsequently reused on-site if already included in quantity
determination
EL
• Hazardous waste produced in process tanks not counted (see
special management practices).
EPA Region 2
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Exhibit X-11
Waste Counting, continued
Recyclable materials explicitly excluded from the hazardous
waste regulations under 261.6(a)(3) not counted.
Hazardous waste remaining in an empty container or an inner
liner removed from an empty container not counted (see
special management practices section)
PCB wastes regulated under Toxic Substances Control Act are
not counted.
Hazardous wastes which are managed immediately upon
generation only in on-site elementary neutralization units,
wastewater treatment units, or totally enclosed treatment
facilities are not counted.
EPA Region 2
12
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Exhibit X-12
Waste Counting, continued
Hazardous waste that is recycled, without prior storage or
accumulation, ony
w*
under 40 CFR 261.6
a
te process subject to regulation
A *J \-s
are not counted.
.
Hazardous waste that is used oil managed under the
requirements of 40 CFR 261.6(a)(4) ar
not counted.
d 40 CFR part 279 is
Spent lead batteries managed under the requirements of 40
CFR part 266 subpart G are not counted.
EPA Region 2
13
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Exhibit X-13
EPA ID Number
RequirementflJ SQGs and LQGs H
NJ also requires numbers for certain CE-SQGs
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
EPA ID numbers can be obtained from EPA Region 2 offices:
call (212) 637-4106 -'
EPA Region 2
14
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Exhibit X-14
Quantity Limits For Non-Acute
Hazardous Wastes
• CE-SQGs can an
at any time
ate on-site up to 1,000 kg or 2,200 Ibs
SQGs can accumu
any time
LQGs have n
,000 kg or 13,200 Ibs at
EPA Region 2
15
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Exhibit X-15
Quantity Limits For Acute Hazardous
Wastes
CE-SQGs and SQGs can accumulate on-site less than 1 kg at
any time
CE-SQGs and SQGs
of spill debris
LQGs have n
n-site less than 100 kg
EPA Region 2
16
-------
Exhibit X-16
Time Limits
CE-SQGs
o
• til
mit
SQGs can store waste no more than 180 days (270 days if
TSDF is more than 200 miles away
* L ^^
LQGs can store waste no more than 90 days without a permit
EPA Region 2
-------
Exhibit X-17
Proper Management
SQGs and LQGs
when adding or removi
secured from failure
SQGs and LQ
book entries
HW containers sealed (except
aste), in good condition and
inspections with log
EPA Region 2
18
-------
Exhibit X-18
Proper Management, continued
SQGs and LQGs
ainer with:
'Hazardous Wast*
i
-------
Exhibit X-19
Emergency Planning
LQGs and SQGs
communication sy
e an adequate internal alarm or
small facilities.
ergency Coordinator
who is on the premises or on-call at all times.
EPA Region 2
20
-------
Exhibit X-20
Emergency Planning, continued
LQGs and SQGs must have a telephone at the site for calling
emergency assistance and post emergency response
information by the phone, including the name, office, and
home phone numbers, and address of the emergency
coordinator.
LQGs and SQus mus
emergency response.
uate aisle space for
EPA Region 2
-------
Exhibit X-21
Emergency Planning, continued
SQGs and LQGs must ensure adequate water for fire fighting
SQGs and LQGs must have available, know the location of,
and maintain:
• Fire extinguishers and alarms
• Spill control mal
iClfr^f i
• Decontamination supplies
EPA Region 2
22
-------
Exhibit X-22
Emergency Planning, continued
SQGs and LQGs
arrangements
• Fire department
e advanced emergency
Police departmen
t5]fV
Emergency resp
iClfr^f
Equipment suppliers & emergency contractors (often
handled by transporter/TSDF)
Hospitals
EPA Region 2
23
-------
Exhibit X-23
Emergency Planning, continued
LQGs are re<
which must b<
contingency plan
inimize hazards from fires,
explosions, or any unplanned release of hazardous waste or
constituents I g=y^ —*^F J
ept on-site and an additional copy
1 emergency service providers
A copy of the plan mus
* ^y^^^^^. ^E*
must be submitted to ;
EPA Region 2
24
-------
Exhibit X-24
Personnel Training
SQGs must e
with proper waste
(262.34(d)(5)(iii
ban
employees are thoroughly familiar
nd emergency procedures
training requirements
his requires initial training and
^.
LQGs must c
in 265.16 an(
annual review that teaches proper waste management and
familiarizes them with the procedures, equipment and systems
to effectively respond to emergencies.
EPA Region 2
25
-------
Exhibit X-25
Hazardous Waste Minimization
LQGs are re
volume and toxicity o;
a program in place to reduce the
te generated to the degree
economically practicable, and must select a currently available
treatment, storage, or disposal method that minimizes present
and future threat;
SQGs must make a good faith effort to minimize waste
generation and to select the best available waste management
o o
EPA Region 2
26
-------
Exhibit X-26
Hazardous Waste Minimization
Generator's Certificai
• If I am a large quantity generator, I certify that I have a program
in place to reduce the volume and toxicity of waste generated to
the degree that I have determined to be economically practicable
and that I have selected the practicable method of treatment,
storage, or disposal currently available to me which minimizes
the present and future threat to human health and the
• If I am a small quantity generator, I have made a good faith effort
to minimize my waste generation and select the best waste
management method that is available to me and that I can afford.
EPA Region 2
27
-------
Exhibit X-27
Maintenance and Operation
IS
40 C.F.R. Se
264.31 and 265.31 requires
generators and TSDFs to maintain and operate their facilities
to minimize the possibility of a fire, explosion, or any
unplanned sudden or non-sudden release of hazardous waste
.
or hazardous waste constituents to air, soil, or surface water,
which could threaten human health or the environment.
EPA Region 2
28
-------
Exhibit X-28
EPA Region 2
29
-------
Exhibit X-29
EPA Region 2
30
-------
Exhibit X-30
EPA Region 2
31
-------
Exhibit X-31
Shipping Waste Off Site
CESQGs must e
following typ
Permitted or In
elivery of waste to one of the
TSDF
V^v ^^^^- ^ _^i
A facility authorized by the state to handle municipal, or
j J r
industrial wastes
A recycle
EPA Region 2
32
-------
Exhibit X-32
Shipping Waste Off Site, continued
SQGs or LQ
or recycling facility
SQGs and LQGs
are properly pa
d, labeled, m;
7 7
CRA-permitted TSDF
rdous waste shipments
, and placarded to
DOT regulations (usually done by transporter)
EPA Region 2
33
-------
Exhibit X-33
Shipping Waste Off Site, continued
SQGs and LQGs must prepare hazardous waste manifests
correctly, keep all copies for at least 3 years, track signed
TSDF copies, sign a certification of hazardous waste
minimization on the manifest and send copies where required
on form
SQGs and LQ
rdous waste meets the
irements and send the
EPA Region 2
34
-------
Exhibit X-34
Shipping Waste Off Site, continued
fl
Final Rule - Marc
ew manifest form
.—^ , ^ r_ _J
http://www.epa.gov/epaoswer/hazwaste/gener/manifest/mods.htm
Standardize the content and appearance of the manifest form and
continuation sheet (Forms 8700-22 and 22a);
Make it consistent
Add a unique tracking number;
Allow an "agent" to sign manifest;
Make the forms available from a greater number of sources; and
EPA Region 2
35
-------
Exhibit X-3 5
Shipping Waste Off Site, continued
Adopt new procedures fo
shipments with the
include:
hazardous wastes that
wastes enten
racking certain types of waste
These types of shipments
acilities reject,
wastes consisting of residues from non-empty hazardous
waste conl
nited States.
EPA Region 2
36
-------
Exhibit X-36
Shipping Waste Off Site, continued
'here wil be i
this 18 month period.
form.
>nth transition to the new form. During
iers and states will only use the old
After September 5, 2006, only the
requirements established under this
acceptable for u
manifest form and
l rule will be valid and
Handlers will obtain new forms from any source that has
registered with EPA to print and distribute the form. A
handler can use a manifest from any registered source.
EPA Region 2
37
-------
Exhibit X-37
Shipping Waste Off Site, continued
The regulations
transporters in 40
proposal.
•^•••^^^ m^
Related requirements for
storage, and disposa
affected, along with
ous waste generators and
are affected by this
owners and operators of treatment,
arts 264-265 are also
acuities
irements in Part 271.
E-Manifest delayed - will be addressed in future rulemaking
EPA Region 2
38
-------
Exhibit X-3 8
Biennial Report
LQGs must su
3mit a Biennial Report to their EPA Regional
office (annual in NY State) by March 1 of every even-
numbered year which includes the:
!^^]_J_
EPA ID number, name, and address of the generator, and
every transporter,' TSDF and recycler used
• Descriptio
Actions taken to reduce the volume and toxicity of the
waste, and the results of those actions
EPA Region 2
39
-------
Exhibit X-39
Mixtures
CESQG limitations continue even if the CESQG hazardous
waste mixed with solid waste exceeds the quantity
i j
limitation
§261.5(h)
•EPA determined that CESQG's should not be "penalized" if they mix their limited amount of CESQG hazardous waste with other solid waste.
•The rationale is that these small quantities would be mixed with solid wastes anyway when they are managed in municipal or non-hazardous industrial waste
facilities.
EPA Region 2
40
-------
Exhibit X-40
Mixtures (continued)
• There are two exceptions regarding mixtures of CESQG
wastes with solid waste:
- If the mixture exceeds the quantity limitations, and it
exhibits a characteristic, it is subject to full Subtitle C
regulation
- If small quantity generator hazardous waste is mixed
with used oil and the resultant mixture is to be used for
energy recovery, the mixture is subject to Part 266,
Subpart E rrnihtirnV^i^^ ^ §261.5(1)
§261.50)
•There are two situations where EPA felt that mixtures of CESQG waste and solid waste should be regulated.
•The first is where the mixture exhibits a hazardous waste characteristic (I,C,R,T). The entire mixture must be managed as regulated hazardous waste -
which makes intuitive sense.
•The second is where the waste is mixed with used oil, and then used for energy recovery. Used oil contaminated with even small amounts of hazardous
waste, poses certain environmental risks when burned, therefore, the Agency felt these mixtures should be regulated in the same manner as other used
oil - if the oil was to be burned for energy recovery.
EPA Region 2 41
-------
Exhibit X-41
Typical Hospital Hazardous Waste
lercury-containing items
Includes whole items and spill residues
Photographic/X-Ray fixer solutions
Silver recovered from fixer, if not recycled
X-Ray Film containing silver or other metals
I ^i^r "*\ V"""™i^^V"^i _ 3^[^ ^-J
Ethanol and formaldehyde/ethanol solutions
Spent, off-spec, or excess laboratory chemicals
(solvents, acids, bases, etc.)
Chemotherapy drugs
EPA Region 2
42
-------
Exhibit X-42
Typical Hospital Hazardous Waste
(continued)rm
IH H
• Waste, e:
products
g^^ _^*N^
• Fluorescent light bulbs, if not managed as
Universal Wastes
-spec paints and cleaning
Other types include high-intensity discharge
(HID), neon, mercury vapor, high pressure
sodium, and metal halide lamps
Batteries, if not managed as Universal Wastes
EPA Region 2
43
-------
Exhibit X-43
Typical Hospital Hazardous Waste
(continued)
ut< .
lead-bearing electronics
Lead aprons and shielding
Computer
, circuit boards, and other
cathode ray tube (CRT) screens
Incluc
[3
Compressed gases (generally, any that are
ignitabl
Waste pesticides, fungicides, etc.
EPA Region 2
44
-------
Exhibit X-44
Relevant Federal Regulations
40 CFR Section 261.
40 CFR Section
EPA Region 2
45
-------
Exhibit X-45
/^VJ-1 /^
Other Guidan
Guidan
or Status
EPA Region 2
46
-------
Exhibit XI-46
Contacts for This Course
Kathleen Malone
+212-637-4083
+malone. kathleen@epa.gov
John Gorman
+212-637-4008
^^^^^^^^^^^^^^m ^^J^
gorman.iohn@epa.gov
EPA Region 2 47
-------
Exhibit XI
Special Management Practices
Overheads from Presentations
Relevant Federal Regulatory Citations
RCRA Policy Excerpts
EPA Region 2
-------
Exhibit XI-1
Hazardous Waste Handled Under
Special Management Practices
•There are several points addressed in the regulations which do not "neatly" fit into the flow charts.
•These basically go to the question of when a hazardous waste becomes regulated.
EPA Region 2
-------
Exhibit XI-2
Hazardous Wastes Produced In
Process Tanks
• A hazardous waste generated in a product or raw material
storage tank, transport vehicle, pipeline or process unit is
not subject to regulation until it exits the unit
Exceptions: .
Unit is a surface impoundment
90 days after unit ceases to be operational
§261.4(c)
•The reason for this distinction is to ensure that RCRA doesn't force every process tank under its jurisdiction.
•Without this clarification, any tank or pipe with hazardous sludge at the bottom could be considered a hazardous waste storage tank.
•The exceptions to the rule are to ensure:
- No wastes inadvertently escapes to the environment.
- Process tanks taken out of service do not hold hazardous waste without any management. If wastes are not removed within 90 days, the tank is a
regulated unit and requires a permit.
^^^^^^^H
EPA Region 2
-------
Exhibit XI-3
Containers May Also Be Regulated
• If they formerly held a hazardous waste, and
• If the container is not "empty"
§261.7(a)
•Similarly, there needed to be a clarification on when containers formerly holding hazardous waste may be considered to be hazardous waste.
•The purpose is to ensure all hazardous wastes - and their residues in tanks and drums are properly regulated.
EPA Region 2
-------
Exhibit XI-4
A Container Is "Empty" If
For compressed gas, the pressure in container = atmospheric pressure
For acute hazardous waste, the container or inner liner is:
Triple rinsed
Cleaned using equivalent method
Inner liner removed
Hospital Examples:
• Containers of arsenic (PO12)
• Canisters of osmium tetroxide (P087)
• Vials of epinephrine (P099)
•The first is obvious. If the container is at atmospheric pressure, no materials will leave or enter the container. 89^1
•For the "P -listed" wastes, there is concern that even small amounts are hazardous. Therefore, the triple-rinse requirement. «>
•Federal rules exempt epinephrine syringes and nicotine patches. From 54 FR 3 1335, 3 1336 (July 28, 1989), drug residues residues
remaining in a dispensing instrument to have been used for their intended purpose. The epinephrine remaining in the syringe, therefore, is not a commercial
chemical product and not a P042 hazardous waste. It could be a RCRA hazardous waste, however, if it exhibits a characteristic of
hazardous waste.
C\\
\ )
EPA Region 2
-------
Exhibit XI-5
A Container Is "Empty" If (Cont'd)
• For other hazardous wastes
- Container or inner liner has been emptied using common
practices (e.g., pouring, pumping, and aspirating) AND
- Holds no more than the following amounts of the wastes
i 2.5 cm, or
i 3.0% by weight (if container < 110 gallons), or
i 0.3% by weight (if container > 110 gallons)
§261.7(b)(l)
•The amounts were added to reconfirm the need to completely empty the container.
•They were also added to facilitate enforcement of the requirement.
•Common practices include pouring, pumping, and aspirating.
EPA Region 2
-------
Exercise #3
Empty Containers
EPA Region 2 7
-------
Exhibit XI-6
Reverse Distribution
• Allows the return of unused Pharmaceuticals to the manufacturer or
reverse distributor as a product (i.e., determination to discard is made at
the reverse distributor)
• Allows the return of unused Pharmaceuticals
• Waste determination is made at the reverse distributor
• Prohibits the shipping of items that are known to be wastes
• Policy Memos:
- Merck-1981
- BFI Pharmaceutical - 1991
Returns Industry Association
www.returnsindustry.com
EPA Region 2
-------
Exhibit XI-7
Laboratories
• States and local municipalities often regulate
wastewater discharges
**
May also regulate lab fume hood exhausts through a
permitting system
44
Sink Disposal" issues
Lab Packs
44
Spring Cleaning" issues
Environmental Resource
e for Small Laboratories
www.epa.gov/sbo/labguide.htm
EPA Region 2
-------
Exhibit XI-8
EPA Region 2
10
-------
Exhibit XI-9
11
-------
Exhibit XI-10
EPA Region 2
12
-------
Exhibit XI-11
13
-------
Exhibit XI-12
hood as posable but do not bloc i
at leas! 4 inches away
12 s equipment in the hood
'arge equipment on stands.
Confirm proper operation of hood before use.
e hood "ON" dunrvg expenmenialran and storage o(
Ch-
Department of Hearth & Environmental Safety, Ext
• Tialfunctiort.
DO NOT USE PERCHLORIC ACID IN THIS HOOD
department ol Heaah and Emiftximftnuit Salstj
5per.ni Butfing
596-3059.3086
EPA Region 2
14
-------
Exhibit XI-13
EPA Region 2
15
-------
Exhibit XI-14
[s&j
EPA Region 2
16
-------
Exhibit XI-15
EPA Region 2
17
-------
Exhibit XI-16
Laboratories Pack 49 CFR § 173.12
Definition: A number of small containers (i.e. jugs and
bottles) of hazardous waste, are individually packaged in
a traditional 55 gallon drum
This eliminates the need to transfer wastes and reduces
the potential for mixing incompatible materials; but
This is often the most expensive method
EPA Region 2
18
-------
Exhibit XI-17
Incompatible Wastes
The term incompatible waste refers to a hazardous waste
which is unsuitable for:
(1) Placement in a container because it may cause corrosion
or decay of the container or inner liner; or
(2) Commingling with another waste or material under
uncontrolled conditions because it might produce
heat or pressure, fire or explosion, violent reaction,
toxic dusts, mists, fumes or gases, or flammable fumes or
gases (Section 260.10) L ^^
Containers used to store hazardous waste must be made of or
lined with materials that will not react with and are otherwise
compatible with the waste in the container (Sections
264/265.172)
EPA Region 2 19
-------
Exhibit XI-18
EPA Region 2
20
-------
Exhibit XI-19
EPA Region 2
21
-------
Exhibit XI-20
Kegion 2.
-------
Exhibit XI-21
Incompatible Wastes (Cont'd)
Incompatible wastes and materials must not be placed in the same
container (Sections 264/265.177)
This requirement includes unwashed containers that previously
held an incompatible waste or material. Incompatible wastes or
materials can only be mixed in a manner that will not cause an
adverse reaction, such as an explosion or uncontrolled flammable
fumes (Sections 264/265. 17(b))
Appendix V in Part 264/265 provides a list of potentially
incompatible wastes. The list is not intended to be exhaustive.
Adequate analysis should be performed to avoid creating
uncontrolled hazards such as heat generation, violent reaction, fire,
explosion, and generation of flammable or toxic gases.
EPA Region 2 23
-------
Exhibit XI-22
Incompatible Wastes (Cont'd)
• Additional Sources of information on incompatible wastes
are:
- Naval Occupational Safety and Health, and
Environmental Training Center
I http://www.norva.navy.mil/navosh/chartnew.htm
- NOAA's Chemical Reactivity Worksheet
i http://response.restoration.noaa.gov/chemaids/react.
EPA Region 2 24
-------
Exhibit XI-23
*i ,-s WAS
ntf,
EPA Region 2
25
-------
Exhibit XI-24
"A/ARI s \\
M k
£
EPA Region 2 26
-------
Exhibit XI-25
EPA Region 2
27
-------
Exhibit XI-26
EPA Region 2
28
-------
Exhibit XI-27
EPA Region 2
29
-------
Exercise #4
Incompatible Materials
EPA Region 2 30
-------
Exhibit XI-28
Satellite Accumulation Areas (262.34c)
• HW generators may accumulate 55 gallons of HW or one
quart of acute HW in containers at or near any point of
generation where wastes initially accumulate, which is
under the control of the operator of the process
generating the waste, without a permit or interim status
^v
provided
• The container is in good condition
• The waste is compatible with the container and only
other compatible wastes will be added to the container
EPA Region 2 31
-------
Exhibit XI-29
Satellite Accumulation Areas (Cont'd)
• The container is always kept closed except when waste is
being added or removed
• The container is marked either with the words "Hazardous
Waste" or with other words that identify the contents of the
container *• ***^ 1^
• Once the above volume limits are exceeded, you must
remove the waste (to an accumulation point, permitted
storage, or ship the waste off-site), within three days
• You must also comply with any additional state
requirements, as applicable
EPA Region 2 32
-------
Exhibit XI-30
EPA Region 2
33
-------
Exhibit XI-31
EPA Region 2
34
-------
Exhibit XI-32
EPA Region 2
35
-------
Exhibit XI-33
36
-------
Exercise #5
Satellite Accumulation Areas
EPA Region 2
37
-------
Exhibit XI-34
90-Day Storage Areas
• 40 CFR § 262.34 allows_a facility to accumulate any
quantity of waste in containers, tanks, drip pads, and
containment buildings for up to 90 days without a
permit, provided that you meet the technical standards
for the containment unit
IHi 1—u
• LQGs that meet all technical standards for hazardous
waste accumulation also may treat the waste without
obtaining a RCRA permit
EPA Region 2 38
-------
Exhibit XI-3 5
90-Day Storage Areas (Cont'd)
• Generators must clearly mark the date that accumulation begins
on each container storing hazardous waste so that it is visible for
inspection
LQGs are also responsible for complying with "preparedness and
prevention" requirements in the event of emergencies. In
± A <-J
addition, you must prepare a written contingency plan and train
employees on hazardous waste management and emergency
response
If you accumulate wastes for more than 90 (or 180) days, it is
considered a storage facility and must follow regulations
described in 40 CFR Parts 264 and 270, unless you have been
granted an extension by your EPA Regional Administrator
EPA Region 2
39
-------
Exhibit XI-3 6
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)
(^x
• Be wary of RCRA hazardous wastes that may not reach
treatment plants (e.g., volatilization or pipe leaks)
EPA Region 2 40
-------
Exhibit XI-37
EPA Region 2
41
-------
Exhibit XI-38
EPA Region 2
42
-------
Exhibit XI-39
EPA Region 2
43
-------
Exhibit XI-40
EPA Region 2
44
-------
Bulb Crushers
Exhibit XI-41
EPA Region 2
45
-------
Bulb Crushers
Exhibit XI-42
EPA Region 2
46
-------
Exhibit XI-43
RCRA Treatment - Definition
40 CFR§ 260.10 definition:
4> Treatment means any method, technique, or process,
including neutralization, designed to change the physical,
chemical, or biological character or composition of any
hazardous waste so as to neutralize such waste, or so as
to recover energy or material resources from the waste, or
so as to render such waste non-hazardous, or less
hazardous; safer to transport, store, or dispose of; or
amenable for recovery, amenable for storage, or reduced in
volume.
EPA Region 2 47
-------
Exhibit XI-44
RCRA Treatment - Requirements
40 CFR§ 262.1
+ (c) A generator who treats, stores, or disposes of
hazardous waste on-site must only comply with
the following sections of this part with respect to
that waste: Section 262.11 for determining
whether or not he has a hazardous waste,
§262.12 for obtaining an EPA identification
number, §262.34 for accumulation of hazardous
waste, §262.40 (c) and (d) for recordkeeping,
§262.43 for additional reporting, and if applicable,
§262.70 for farmers.
EPA Region 2 48
-------
Exhibit XI-45
RCRA Treatment - No Permit
Required for These Activities
40 CFR § 264.1(g) The requirements of this part do not apply to:
(3) A generator accumulating waste on-site in compliance with
§262.34 of this chapter; m lL 1 ^
(5) The owner or operator of a totally enclosed treatment facility,
as defined in §260.10.[M \M ^m
6) The owner or operator of an elementary neutralization unit or a
wastewater treatment unit as defined in §260.10 of this chapter,
provided that if the owner or operator is diluting hazardous
ignitable (D001) wastes (other than the D001 High TOC
Subcategory defined in §268.40 of this chapter, Table Treatment
Standards for Hazardous Wastes), or reactive (D003) waste, to
remove the characteristic before land disppsal, the
owner/operator must comply with the requirements set out in
§264.17(b).
EPA Region 2 49
-------
Exhibit XI-46
RCRA Treatment - Accumulation
Time
§ 262.34 Accumulation timdl
TT
(a) Except as provided in paragraphs (d), (e), and (f) of this
section, a generator may accumulate hazardous waste on-site for
90 days or less without a permit or without having interim status,
provided that: I t M
(1) The waste is placet
(i) In containers and the generator complies with the
applicable requirements of subparts I, AA, BB, and CC of
40 CFR part 265; and/or
(ii) In tanks and the generator complies with the
applicable requirements of subparts J, AA, BB, and CC of
40 CFR part 265 except §§265.197(c) and 265.200;
EPA Region 2 50
-------
Exhibit XI-47
RCRA Treatment - Definition
40 CFR§ 260.10 definition
Totally enclosed treatment facility means a facility
for the treatment of hazardous waste which is
directly connected to an industrial production
process and which is constructed and operated in
a manner which prevents the release of any
hazardous waste or any constituent thereof into
the environment during treatment. An example is
a pipe in which waste acid is neutralized.
EPA Region 2 51
-------
Exhibit XI-48
RCRA Treatment - Definition
40 CFR§ 260.10 definition:
+ Elementary neutralization unit means a device which:
<** (1) Is used for neutralizing wastes that are hazardous only
because they exhibit the corrosivity characteristic defined in
§261.22 of this chapter, or they are listed in subpart D of part
261 of the chapter only for this reason; and
ystem, container,
transport vehicle, or vessel in §260.10 of this chapter.
EPA Region 2 52
-------
Exhibit XI-49
RCRA Treatment - Definition
40 CFR§ 260.10 definition:
Tank means a stationary device, designed to
contain an accumulation of hazardous waste
which is constructed primarily of non-earthen
materials (e.g., wood, concrete, steel, plastic)
which provide structural support.
Tank system means a hazardous waste storage
or treatment tank and its associated ancillary
equipment and containment system.
EPA Region 2 53
-------
Exhibit XI-50
RCRA Treatment - Definition
40 CFR§ 260. 10 definition:
4> Container means any portable device in which a material is
stored, transported, treated, disposed of, or otherwise
handled. I If %l J
4> Transport vehicle means a motor vehicle or rail car used for
the transportation of cargo by any mode. Each cargo-
carrying body (trailer, railroad freight car, etc.) is a separate
transport vehicle. J
Vessel includes every description of watercraft, used or
capable of being used as a means of transportation on the
water.
EPA Region 2 54
-------
Exhibit XI-51
RCRA Treatment - Definition
40 CFR§ 260.10 definition:
Wastewater treatment unit means a device which:
I \i \l 3
^ (1) Is part of a wastewater treatment facility that is subject to
regulation under either section 402 or 307(b) of the Clean
Water Act; and
<** (2) Receives and treats or stores an influent wastewater that
is a hazardous waste, or that generates and accumulates a
wastewater treatment sludge that is a hazardous waste, or
treats or stores a wastewater treatment sludge which is a
hazardous waste; and
<** (3) Meets the definition of tank or tank system.
EPA Region 2 55
-------
Exhibit XI-52
RCRA Treatment - Examples
Evaporation/Dehydration
pH Adjustment
Chemical Reaction
Crushing, mixing,
shredding
Precipitation
Solidification/pozzolanic
stabilization
Biological reaction
Distillation
Burning/incineration
Dilution
EPA Region 2
56
-------
Exhibit XI-53
LDR-
40 CFR § 268.1 Purpose, scope, and applicability:
+ (a) This part identifies hazardous wastes that are restricted
from land disposal and defines those limited circumstances
under which an otherwise prohibited waste may continue to
be land disposed.
I ,
4> (b) Except as specifically provided otherwise in this part or
part 261 of this chapter, the requirements of this part apply
to persons who generate or transport hazardous waste and
owners and operators of hazardous waste treatment,
storage, and disposal facilities.
EPA Region 2 57
-------
Exhibit XI-54
LDR-
40 CFR § 268.1 Purpose, scope, and applicability:
4> 3) Wastes that are hazardous only because they exhibit a
hazardous characteristic, and which are otherwise
prohibited under this part, or part 148 of this chapter, are
not prohibited if the wastes:
9d IT tne wastes:
sposed into a nonhazardous c
(i) Are disposed into a nonhazardous or hazardous injection
well as defined under 40 CFR 146.6(a); and
(ii) Do not exhibit any prohibited characteristic of hazardous
waste identified in 40 CFR part 261, subpart C at the point of
injection.
EPA Region 2 58
-------
Exhibit XI-5 5
LDR-
40 CFR § 268.1 Purpose, scope, and applicability:
+ (4) Wastes that are hazardous only because they exhibit a
hazardous characteristic, and which are otherwise prohibited
under this part, are not prohibited if the wastes meet any of the
following criteria, unless the wastes are subject to a specified
method of treatment other than DEACT in §268.40, or are D003
reactive cyanide ^^^ Vl ^^
^ (i) The wastes are managed in a treatment system which
subsequently discharges to waters of the U.S. pursuant to a
permit issued under section 402 of the Clean Water Act; or
«= (ii) The wastes are treated for purposes of the pretreatment
requirements of section 307 of the Clean Water Act; or
EPA Region 2 59
-------
Exhibit XI-56
LDR-
(iii) The wastes are managed in a zero discharge system
engaged in Clean Water Act-equivalent treatment as defined
in §268.37(a);
an; ,,
no lonqer exhibit a ore
(iv) The wastes no longer
at the point of land disposal (i
impoundment).
prohibited characteristic
placement in a surface
EPA Region 2
60
-------
Exhibit XI-57
LDR-
• 40 CFR § 268.40 Applicability of treatment standards.
(a) A prohibited waste identified in the table "Treatment
Standards for Hazardous Wastes" may be land disposed only if it
meets the requirements found in the table. For each waste, the
table identifies one of three types of treatment standard
requirements: • mj % I ^m
^(1) All hazardous constituents in the waste or in the treatment
residue must be at or below the values found in the table for
that waste ("total waste standards"); or
T
^(2) The hazardous constituents in the extract of the waste or
in the extract of the treatment residue must be at or below the
values found in the table ("waste extract standards"); or
EPA Region 2 61
-------
Exhibit XI-5 8
LDR-
(3) The waste must be treated using the technology specified
in the table ("technology standard"), which are described in
detail in §268.42, Table 1—Technology Codes and
Description of Technology-Based Standards.
EPA Region 2
62
-------
Exhibit XI-59
LDR-
. 40 CFR § 268.40 Applicability of treatment standards.
(b) For wastewaters, compliance with concentration level
standards is based on maximums for any one day, except for
D004 through D011 wastes for which the previously promulgated
treatment standards based on grab samples remain in effect. For
all nonwastewaters, compliance with concentration level
standards is based on grab sampling. For wastes covered by the
waste extract standards, the test Method 1311, the Toxicity
Characteristic Leaching Procedure found in "Test Methods for
Evaluating Solid Waste, Physical/Chemical Methods", EPA
Publication SW-846, as incorporated by reference in §260.11,
must be used to measure compliance. An exception is made for
D004 and D008, for which either of two test methods may be
used: Method 1311, or Method 1310, the Extraction Procedure
Toxicity Test. For wastes covered by a technology standard, the
wastes may be land disposed after being treated using that
specified technology or an equivalent treatment technology
approved by the Administrator under the procedures set forth in
§268.42(b). 151 EPA Region 2 63
-------
Exhibit XI-60
LDR-
40 CFR § 268.40 Applicability of treatment standards.
•0 Applicability of treati
(e) For characteristic wastes (D001-D043) that are subject
to treatment standards in the following table "Treatment
Standards for Hazardous Wastes," and are not managed in
a wastewater treatment system that is regulated under the
Clean Water Act (CWA), that is CWA-equivalent, or that is
injected into a Class I nonhazardous deep injection well, all
underlying hazardous constituents (as defined in §268.2(i))
must meet Universal Treatment Standards, found in
§268.48, Table Universal Treatment Standards, prior to
land disposal as defined in §268.2(c) of this part.
EPA Region 2 64
-------
Exhibit XI-61
LDR-
40 CFR § 268.40 Applicability of treatment standards.
forF001-F005i
f) The treatment standards for F001-F005 nonwastewater
constituents carbon disulfide, cyclohexanone, and/or methanol
apply to wastes which contain only one, two, or three of these
constituents. Compliance is measured for these constituents in
the waste extract from test Method 1311, the Toxicity
Characteristic Leaching Procedure found in "Test Methods for
Evaluating Solid Waste, Physical/Chemical Methods", EPA
Publication SW-846, as incorporated by reference in §260.11. If
the waste contains any of these three constituents along with any
of the other 25 constituents found in F001-F005, then
compliance with treatment standards for carbon disulfide,
cyclohexanone, and/or methanol are not required.
EPA Region 2 65
-------
Exhibit XI-62
LDR-
40 CFR § 268.40 Applicability of treatment standards.
4> (h) Prohibited D004-D011 mixed radioactive wastes and
mixed radioactive listed wastes containing metal
constituents, that were previously treated by stabilization to
the treatment standards in effect at that time and then put
into storage, do not have to be re-treated to meet treatment
standards in this section prior to land disposal.
EPA Region 2 66
-------
Exhibit XI-63
LDR-
40 CFR § 268.42 Treatment standards expressed as
specified technologies, m % I J
Table 1 - Technology Codes and Description of
Technology-Based Standards^ I M
4> DEACT: Deactivation to remove the hazardous
characteristics of a waste due to its ignitability, corrosivity,
and/or reactivity, ^mm I •
4> NEUTR: Neutralization with the following reagents (or
waste reagents) or combinations of reagents: (1) Acids; (2)
bases; or (3) water (including wastewaters) resulting in a
pH greater than 2 but less than 12.5 as measured in the
aqueous residuals.
EPA Region 2 67
-------
Exhibit XI-64
LDR-
40 CFR§ 268.2 Definitions
+ (d) N on waste waters are wastes that do not meet the
criteria for waste waters in paragraph (f) of this section.
+ (f) Wastewaters are wastes that contain less than 1% by
weight total organic carbon (TOC) and less than 1% by
weight total suspended solids (TSS).
4> (i) Underlying hazardous constituent means any constituent
listed in §268.48, Table UTS—Universal Treatment
Standards, except fluoride, selenium, sulfides, and zinc,
which can reasonably be expected to be present at the
point of generation of the hazardous waste at a
concentration above the constituent-specific UTS treatment
standards.
EPA Region 2 68
-------
Exhibit XI-65
LDR-
40 CFR § 268.48 Universal treatment standards.
Wersal treatment
(a) Table UTS identifies the hazardous constituents, along
with the nonwastewater and wastewater treatment standard
levels, that are used to regulate most prohibited hazardous
wastes with numerical limits. For determining compliance
with treatment standards for underlying hazardous
constituents as defined in §268.2(i), these treatment
standards may not be exceeded. Compliance with these
treatment standards is measured by an analysis of grab
samples, unless otherwise noted in the following Table
UTS.
EPA Region 2 69
-------
LDR-
Exhibit XI-66
Appendix VI to Part 268—Recommended Technologies to Achieve
Deactivation of Characteristics in Section 268.42
ics in Se<
The treatment standard for many characteristic wastes is stated
in the §268.40 Table of Treatment Standards as "Deactivation
and meet UTS." EPA has determined that many technologies,
when used alone or in combination, can achieve the deactivation
portion of the treatment standard. Characteristic wastes that are
not managed in a facility regulated by the Clean Water Act (CWA)
or in a CWA-equivalent facility, and that also contain underlying
hazardous constituents (see §268.2(i)) must be treated not only
by a "deactivating" technology to remove the characteristic, but
also to achieve the universal treatment standards (UTS) for
underlying hazardous constituents.
EPA Region 2 70
-------
Exhibit XI-67
EPA Region 2
71
-------
Exercise #6
Waste Accumulation
EPA Region 2
72
-------
Exhibit XI-68
Best Management Practices (BMPs)
Handle all chemo wastes as HW
waste stream to manage
Reduced training costs
EPA Region 2
73
-------
Exhibit XI-69
Best Management Practices (BMPs)
Reverse distribution
Product management; not waste management
Keep documentation to prove reuse
EPA Region 2
74
-------
Exhibit XI-70
Best Management Practices (BMPs)
Pharmacy as accumulation area
Special marking on regulated chemo containers
Develop standard policy for PPE
EPA Region 2
75
-------
Exhibit XI-71
Best Management Practices (BMPs)
• Top Down Policy Making
- Management supporting good waste
management leads to better compliance records
t—' _L
• Regular Self-Audits \L/.
\ A
• Good Employee Trainin
Operating Room Kits
- Reuse parts of OR kits that are not expired
EPA Region 2
76
-------
Exhibit XI-72
Best Management Practices (BMPs)
Environmentally Preferable Purchasing (EPP)
Mercury Free
PVC Free
EPA Region 2
77
-------
Prioritizing EPP Activities
Exhibit XI-73
Review mission of organization
Review recent problems with:
^Occupational health
^Environmental compliance
+Patient safety
Review environmental costs
Review waste audit data & costs
EPA Region 2 78
-------
Exhibit XI-74
Work with (or create!) a Green Team
• Waste Managers
• Facilities Managers
• Laboratory Managers
• Nursing
• Housekeeping
• Infection Control
• Clinical staff
EPP initiatives will proceed smoothly, be more
accepted by end users if you involve them
throughout, plus you need their information!
EPA Region 2
79
-------
Total Cost
Exhibit XI-725
Purchase Price (x frequency of purchase)
Disposal Cost
Occupational Health Costs
Liability
Environmental Costs
Total Cost
ion 2
80
-------
Exhibit XI-76
Preparing for EPP Action
Start with a product that is already causing
environmental/health/cost problems
Include users when researching alternatives
Set specific performance and environmental
criteria, with verification measures for each
Investigate availability and price of alternatives
Pilot alternative in willing department—find a
champion
EPA Region 2
81
-------
GPO Buying Power
Exhibit XI-77
GPOs have huge contracting advantages:
4> Buying power that makes vendors care
+ Dedicated contracting staff to vet claims
Communicate with your GPO:
4> Request general EPP contracting
+ Request custom EPP contracts
+ Serve on product review committees
EPA Region 2
82
-------
Exhibit XI-78
Develop a comprehensive EPP
program
• Reviewing all contracts allows you to
capture easy improvements
• Comprehensive program balances
higher costs with savings
• Integrate EPP with other environmental
initiatives:
Green Building
Waste reduction
Reuse programs (drop and swap)
EPA Region 2 83
-------
Specific EPP Targets
Exhibit XI-79
Mercury - Clinical, Lab, Building
Waste reduction - solid and hazardous
Resource Efficiency - energy and H2O
Paper
Electronics
Cleaning
Pest Control
Green Building
EPA Region 2 84
-------
Mercury in Healthcare
Exhibit XI-80
Thermometers
Sphygmomanometers
Bougies, dilators, cantor tubes
Batteries, electronics
Barometers Fluorescent bulbs
Switches/thermostats
Laboratory chemicals, fixatives
Pharmaceuticals
EPA Region 2
85
-------
Clinical Mercury Devices
Exhibit XI-81
Alternatives widely available, at equivalent performance, cost
Gastrointestinal tubes
Sphygmomanometers
Thermometers
Calibrating
Manometers
Tungsten or Water
Aneroid or Electronic
Electronic or Alcohol
Electronic
\\
EPA Region 2
86
-------
Mercury in Building Supplies
Exhibit XI-82
•Thermostats, Thermometers, Switches, Relays
contain mercury
•Gas and Water Flow Meters, Float Switches can
contain gallons of mercury
Strategy:
•Specify or request Hg-free alternatives for all new
and replacement parts (available for most
applications)
•Label and require proper EOL handling of Hg-
containing equipment currently in use
EPA Region 2 87
-------
Mercury in Lighting
Exhibit XI-83
ALL fluorescent and HID
lamps contain mercury
Est. 620 million discarded
per year in US =
2-4 tons of mercury
"Green tip" - can have
same Hg content as a
standard lamp
EPA Region 2
88
-------
Exhibit XI-84
Mercury Lighting Strategy
Use fluorescents to reduce power
consumption - reduces Hg
emissions
Require disclosure of mercury
content and choose lower mercury
lamps wherever possible
Recycle ALL fluorescents and HID
lamps
EPA Region 2 'V^ 89
-------
Mercury in the Laboratory
Exhibit XI-85
Histology Fixatives
Histology Stains
Antibodies
Parasitology Fixatives
Automated testing
equipment reagents
Bleach (contaminant)
EPA Region 2
90
-------
Lab Mercury Strategy
Exhibit XI-86
• Eliminate B5/Zenkers stains and others
with readily available alternatives
• Require vendor mercury disclosure for
all products
• Identify high mercury or easily replaced
products
• Prioritize list and develop schedule
to replace as you can
EPA Region 2
-------
Exhibit XI-87
Hidden mercury
• Tilt switches
• Pressure regulators
• Flat panel screens
• Preservatives in Pharmaceuticals
• Fire detection devices
• Neon lights
Strategy:
Require ALL vendors to certify products mercury
free or disclose mercury content, and establish a
mercury free preference
EPA Region 2 92
-------
Exhibit XI-88
Purchasing for Waste Reduction
Almost everything that leaves a facility as waste came
in as a purchase - contracting for waste prevention
is key
Strategies:
• Leasing - carpet, copiers, electronics
• Switch from disposable to reusable - gowns,
drapes, pads, dishware
• Single use device reprocessing
• Custom surgical procedure packs/carts
• Reduced weight paper (double side, reuse)
• Require packaging reduction or takeback
EPA Region 2 93
-------
Exhibit XI-89
Waste Reduction $ucce$$
Foote Health System, Jackson, Ml:
• $56,000 savings in one year from SLID reprocessing
Catholic Healthcare West
• Eliminated newspaper delivery to patients at a savings of
$18,000 and 9,100 tons of waste per year
Bronson Methodist, Kalamazoo, Ml:
• $36,000 saved in one year from switching to reusable gowns
and towels
H2E Award Winner
• Saved $25,000 in acquisition of reusable wash basins and
admission kits, eliminating disposables
Alta Bates Medical Center, Oakland, CA:
• Equipment reuse reduced purchasing and waste disposal
costs by over $53,000
EPA Region 2 94
-------
Purchasing for Hazardous
Waste Reduction
Exhibit XI-90
Alternatives substitution (total cost)
As-needed purchasing for all chemicals
Solvent recovery - alcohol, xylene
Review sterilization vs. high level
disinfection
Least toxic pest control
Mercury-free lab chemicals
EPA Region 2 95
-------
Exhibit XI-91
Hazardous Waste Reduction
$ucce$$
Sparrow Health System, Lansing, Ml:
• EtO alternative system reduces per cycle cost from
$25 to $0.40
H2E Award Winner
• Recycled 520 gallons of formalin with disposal and
purchase savings of $5,700
H2E Award Winner
• Recovered 260 gallons of xylene with $5,800 net
savings per year
Strong Memorial, Rochester, NY
• IPM program saved 1 FTE plus $2000 per year
EPA Region 2 96
-------
Energy and Water Usage
Exhibit XI-92
Hospitals often the largest water and
energy user in town
Highly lit operations 24/7, water-intensive
laundries, cooling towers, food preparation
Costs of energy and water use are huge
Many consultants will work on a "Shared
Savings" basis
EPA Region 2
97
-------
Energy Savings Pay Off
Huge cost savings, short payback
Energy Star:
Contract specifications,
Appliance standards,
Facility benchmarking
Exhibit XI-93
Catholic Healthcare West, with 40 facilities, identified $48
million in energy savings upgrades. Fully implemented,
these will save $12 million per year, for a 4 year payback,
with savings continuing indefinitely
Tfc
-------
Exhibit XI-94
Water Use Reductions
Implement as you build or renovate
FEMP: BMPs, procurement specs
One hospital saved $280 per sink per year by
installing $12 flow reduction device
Another facility saved $20,000 per year by
recirculating heating/AC water
One hospital saved $42,000 per year by installing
ultra low flush toilets
EPA Region 2
-------
Paper Impacts
Exhibit XI-95
U.S. and Canada paper industry releases
220+ million pounds of toxic pollution per year
Virgin wood used for office paper in the US
annually is equivalent to building 900,000
homes
Americans discard 4 million tons of office
paper per year = 12 ft high wall of paper from
NY to CA
Paper use reduction can save tons
of paper, thousands of dollars
EPA Region 2
-------
Exhibit XI-96
Paper Purchasing Strategy
• Reduce paper use/costs
• Negotiate aggressively, use GPO
• Copy paper: spec at least 30% post-
consumer content
• "Processed Chlorine Free"
• Janitorial paper: 50-100% post, unbleached
• Recycle all office paper to 'close the loop'
• HIPPA precautions - source
reduction first!
EPA Region 2
-------
Electronic Waste
Exhibit XI-97
Fastest growing waste stream in the world
4> 3.96 billion Ibs. of consumer electronic waste in 2000
4> ~ 100 million cell phones discarded -50,000 tons per year
- as of 2005
4> ~ 315 to 680 million computers obsolete in US in the next
decade
Those computers contain:
+ 1 billion pounds of lead
4> 1.9 billion pounds of cadmium
+ 400,000 pounds of mercury
\t/
-------
Exhibit XI-98
Best Management Practices (BMPs)
Greener Cleanin
EPA Region 2
103
-------
Exhibit XI-99
"Greener" Janitorial Chemicals
Why be concerned about Cleaners?
+Asthma risk
Occupational skin/eye injuries
Indoor Air quality
Training/Worker protection costs
Patient and staff comfort
35% of cleaning chemicals can cause
blindness, severe skin damage or
damage to organs through skin. 6%
are linked to cancer, ozone depletion
or global warming
EPA Region 2
-------
Green Cleaning Strategy
Exhibit XI-100
Involve all interested parties:
4> Infection Control, Nursing, Purchasing,
Housekeeping/Environmental Services, staff
with occupational health issues
Look for certification
+ Green Seal or equivalent - require verification!
Address routine cleaning first
+ Disinfection issues are more complex, may take
more work
EPA Region 2
-------
Exhibit XI-101
Best Management Practices (BMPs)
Minimize Pesticides
EPA Region 2
106
-------
Exhibit XI-102
Pesticide Health Effects
Acute: nausea, dizziness, headaches,
aching joints, mental disorientation,
vomiting, convulsions, skin irritation,
flu-like symptoms and breathing
problems.
Chronic: cancer, birth defects, genetic
damage, neurological, psychological
and behavioral effects, blood
disorders, chemical sensitivities,
reproductive effects, and abnormalities
in liver, kidney, and immune system
function.
Numerous environmental impacts
EPA Region 2
-------
Exhibit XI-103
IPM - A Proven Alternative
• Scouting and treatment thresholds
+ No routine treatment
• Nonchemical methods
+ Good sanitation practices
4> Structural maintenance
• Least toxic controls
+ Minerals, soaps, boric acid
+ Enclosed baits, crack and crevice
treatments
• No treatment while spaces are
inhabited
Detailed plan and specifications are essential
EPA Region 2
108
-------
Exhibit XI-104
Best Management Practices (BMPs)
Minimize Red B
- Put regular solid waste in regular trash
• Know Where Your Waste Is:
Tracking
Computer
EPA Region 2
109
-------
Exhibit XI-105
Best Management Practices (BMPs)
Green Buildings
EPA Region 2
110
-------
Green Guidelines for
Healthcare Construction
Exhibit XI-106
Green Guidelines
r Healthcare Cons [ruction
About the Green Guidelines for Healthcare Construction™
Objectives
Healthcare facilities present both a challenge and opportunity in the development and implementation of sustainable construction.
Issues such as 24/7 operations, energy and water use intensity, chemical use, infection control requirements and formidable
regulatory requirements can pose significant obstacles to the implementation of currently accepted sustainability protocols.
Furthermore, it is appropriate that guidelines customized for the healthcare sector reflect the fundamental organizational mission to
protect and enhance individual and community health and to acknowledge the intrinsic relationship between the built environment
and ecological health. As the healthcare sector develops a design language for high performance healing environments, it has the
opportunity to highlight the associated health-based benefits and integrate those into the evolving sustainable design standards
across sectors.
The Gieen Guidelines foi Healthcare Constiuctiois""
tool that designers, owners, and operators can use to e1-, J t
While an array of building types are represented in the heaitt
are predominately institutional occupancies as defined b-\ c
requirements have created particular needs. Most of the G
building as well where healthcare concerns are prePc
working in other sectors as well. It applies to new free :
and extensive rehabilitation/adaptive reuse projects.
GGHC follows the credit structure of LEED™ 2.1 and. for manv credits, incomorates identical lanauaae. referencina both the
«:
-------
Exhibit XI-107
Best Management Practices (BMPs)
The Resource Conservation Challenge
^^-
- www.epa.gov/rcc
_L C? ^) I
Performance Track
- www.epa.gov/performancetrack
EPA Region 2
112
-------
Exhibit XI-108
Hazardous Waste Contacts
(EPA Region 2)
• For more information about hazardous waste requirements
for hospitals and healthcare:
- EPA Region 2 RCRA Compliance Branch
i Steven Petrucelli, (212) 637-3129
i General number, (212) 637-4145
- EPA Region 2 Compliance Assistance Program
i Diane Buxbaum, (212) 637-3919
- EPA Region 2 Solid Waste Program
i Lorraine Graves, (212) 637-4099
EPA Region 2 113
-------
Exhibit XI-109
Hazardous Waste Contacts
(Region 2 States)
New York State DEC Hazardous Waste Generator
Hotline (800) 462-6553
New Jersey State DEI Bureau of Solid and Hazardous
Waste Enforcement (609) 584-4250
Caribbean Environmental Protection Division (787) 977-
5865 • *^
EPA Region 2 114
-------
Exhibit XI-110
Relevant Federal Regulations
40 CFR Part 261
261.4(c),(d),(e),(f)
261.7
261.8
40 CFR Parts 264 and 265
Appendix V - Incompatible Wastes
EPA Region 2 115
-------
Exhibit XI-111
Other Guidance
Guidance Material on Special
Management Practices
EPA Region 2 116
-------
Exhibit XI-112
RCRA Policy Excerpts
EPA Region 2 117
-------
Exhibit XI-113
Federal Regulations
EPA Region 2 118
-------
.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
-------
-\ppro
2 following strategies
sectors:
- Compliance
-
nee incentives (voluntary
;closure)
Compliance monitoring
Enforcement
Pollution prevention
Environmental management systems (EMS)
Region 2 Healthcare Compliance
Initiative
-------
-------
Results;; Corr
J _ ^_> ^_x ^>J J —i-—x J ^_^ _X J J .
Dliance Monitoring
Incentives Programs
Enforcement Actions
ormal Enforcement Action
Settlemen
dit Agreements
Voluntary Disclosures
Violations Corrected
Hospitals
480
58
39
14 ($1,529,263)
12 ($646,887)
39
135 covering 528 facilities
($18,623,185 for 94 resolved)
1745
Region 2 Healthcare Compliance
Initiative
-------
Number of Beds
Hospitals
34,453
•mber of Inpatient
Number of Outpatients
Number of Staff
1112914
,,
19.158153
150613
Region 2 Healthcare Compliance
Initiative
-------
Environmental Benefits from Healthcare Disclosures
More than 200,977 Ibs/year of hazardous waste is now being
managed properly because hospitals have self-disclosed
violations and corrected mismanagement.
At least 1,244,878 gallons of oil is now being managed properly.
At least 760 residential units now in compliance with lead-based
paint rules.
At least 156,400 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
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hood as posable but do not bloc i
at leas! 4 inches away
12 s equipment in the hood
'arge equipment on stands.
Confirm proper operation of hood before use.
e hood "ON" dunrvg expenmeniahon and storage ol
Ch-
Department ol Hearth & Environmental Safety, Ext
• malfunction.
DO NOT USE PERCHLORIC ACID IN THIS HOOD
department ol Heaah and Etrvifonmcmutt SalM)
5per.ni Butfing
596-3059.3086
igion 2 Healthcare Complian
Initiative
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Region 2 Healthcare Compliance
Initiative
-------
Region 2 Healthcare Compliance
Initiative
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igion 2 Healthcare Complian
Initiative
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igion 2 Healthcare Complian
Initiative
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i ,_~ .L.I -—^ ~}(<~-
nddJCflCdfd KLr
i i -
JOcJtlon
Breakout of RCRA Violations from Hospital Disclosures
Generator
UST 3% Requirements 7%
Container
Management 27%
ID of HW 25%
General Facility
Standards 12%
Accumulation Time
1%
Universal Waste
18%
Manifest 6%
Region 2 Healthcare Compliance
Initiative
-------
om
^cJDOrar
Dental ell.
X-rayf
areas
Maintenance areas
Physical therapy
Underground storage
tanks
Morgue
Operating rooms
Nursing units
Hazardous waste storage
areas
Medical technology unit
Construction areas
Satellite accumulation
points
Region 2 Healthcare Compliance
Initiative
-------
SEJ
j j x^ >_>j
Breakout of CAA Violations from Hospital Disclosures
Asbestos 6%
SIP (including
MACT, NESHAPS,
& Title V) 41%
CFCs 53%
Region 2 Healthcare Compliance
Initiative
-------
-------
SEJ
J J X^*! >_>J
-------
SEJ
j j x^ >_>j
T ^^P"
D anon
-------
•m 135
Ran I-
A
Violation
ID of HW
Universal Waste
Labeling
CFC Leak Detection
Records
Container
Management
I
itary Disclosures)
Statute Frequency
RCRA 302
RCRA ;
RCRA 1
CM
RCRA
Region 2 Healthcare Compliance
Initiative
-------
•m 135
Rank
SIP Requirements
nical Inventory
ifests
m.
SPCC
I
tary Disclosures)
I Statute Frequency
CM
EPCRA
RCRA
CWA
10 Personnel Training RCRA
Region 2 Healthcare Compliance
Initiative
-------
>m 135
Ran1
violation
1; Detection
Requirements
Empty Containers
CFC - Certified
Technicians
Statute
EPCRA
RCRA
RCRA
RCRA
CM
Frequency
Region 2 Healthcare Compliance
Initiative
-------
rrc
urn Number of Vio
jrii;
num Number of
Violations
Average Number of
Violations
RCRA
EPCRA
CM
CWA
SDWA
Region 2 Healthcare Compliance
Initiative
-------
I • I • I •
acihtie
vyjtr:
a on
From ^
unt
,t?lti]rg
—«^>j -~t -_> j «> ^—-«
RCRA
EPCRA
CM
CWA
SDWA
TSCA
Number of
Facilities
I
Percent of
Facilities
67%
45%
53%
44%
16%
Region 2 Healthcare Compliance
Initiative
-------
als com
nd returned the audit
,
79
C'Tn
b
O 1
10,691 beds are reported to be within these 38
hospitals
• 282 facilities are reported to compose these 3£
hospitals
Region 2 Healthcare Compliance
Initiative
-------
How many staff does your
hospital employ?
P—N
.t* 1 n
•^ 1 U
S 8
O o
ffi
^^ 6
O
^ 4
S9
z
^! n
8
6
2
6
^
»-f
0-250 251-500 501-1000 1000-20002000-3000 >3000
Number of Staff
-------
How many beds does your
hospital have?
^^ y
^ 0
^ o
a" 7
/
2 6
o o
^ 5
o 4
O ^
b ^
-------
QQ
25
20
10
0
How many facilities are part of
your hospital?
I
0 to 5
6 to 10
11 to 25
Number of facilities
I I
26 to 50
-------
What best describes your
status with the
Audit Initiative?
5%
8%
53%
34%
No, did not
participate in Audit
Policy
Yes, audited
without
communicating
with EPA
Yes, signed an
Audit Agreement
with EPA Region 2
Yes, voluntarily
self-disclosed
compliance issues
-------
% of Respondants who found each
Compliance Assistance Activity
?Very Useful1
D 2 1 %
27%
24%
D Workshop s It ram ings
/presentations
Outreach materials
Region 2 web sites
DEPA re sp on ses to
phone calls/em ails
28%
-------
Before And
Comp.ian
Be fo re
After
Region 2 Healthcare Compliance
Initiative
-------
ancles I
High Respon
RCRA
P
After
UST
CM
CWA
SPCC
TSCA
Pesticides
Region 2 Healthcare Compliance
Initiative
-------
r^ i
fri?]
InitiEJti\
'yps of Changs
monitoring
J\,
and O&M
'abeling, and
reporrjf]
mining
Implement P2 and waste
min
EMS
Or The
r.
35%
32%
14%
12%
7%
Region 2 Healthcare Compliance
Initiative
-------
Planne
j i J
•r j i J i j
e Initiati
ype of Change
Paperwork,
reporting
Handling
monitor!
processing,
ig, and O&M
ment P2 and waste
mm
EMS
Training
p
33%
21%
21%
16%
9%
Region 2 Healthcare Compliance
Initiative
-------
avm2 Activiti
ment/segregati
$350,000
emca.
, battery & HW
rosrams
fficiency motors, up-graded
t-8's, and new electronic
r\ <~rr -~i
.d>jl^j
$250,000
$ 1 3 6,000
Disposable RMW containers/bulb crushers $114,000
Changed to reusable sharps containers
$30,000
Region 2 Healthcare Compliance
Initiative
-------
475 tons
'DP equipment
.
reeve
y
n I
ontamers
Integrated pest management
75 tons
10,500 units
80% reduction in
pesticides
Region 2 Healthcare Compliance
Initiative
-------
e Waste
n Ac
coma
J Install water
r| •*
grease to a reclamation fac
jm disposable to reusable plates, eating
sils, and cups for cafeteria services
duce the use of disposable cleaning materials
Region 2 Healthcare Compliance
Initiative
-------
on Mercu
n Ac
eplsicecl mercur
lometers & thermometers
computer monitor and electronics recyclin;
Implemeii!
prograj
ed and recycled amalgam at dentist and silver reclaimi
installed at cancer treatment center
Initiated a hospital-wide mercury reduction and recycling
program
Region 2 Healthcare Compliance
Initiative
-------
What percentage of your
institution was audited?
6% 3%
100%
Greater than %50
Less than %50
91%
Region 2 Healthcare Compliance
Initiative
-------
Did you encounter roadblocks
with the cost of your audit?
Some issues,
but no major
issues
38%
Definite
roadblocks
3%
No
roadblocks
59%
Region 2 Healthcare Compliance
Initiative
-------
Did you encounter roadblocks
with the cost of compliance ?
Definite
roadblocks
9%
Some issues,
but no major
issues
54%
No
roadblocks
37%
Region 2 Healthcare Compliance
Initiative
-------
Did you encounter roadblocks
with upper management when
implementing your audit?
Definite
Roadblocks
3%
Some issues,
but no major
issues
17%
No
roadblocks
80%
Region 2 Healthcare Compliance
Initiative
-------
Did you encounter roadblocks with
identifying appropriate contractors
when implementing your audit?
Some issues, Definite
but no major roadblocks
issues go/0
28%
No
roadblocks
64%
Region 2 Healthcare Compliance
Initiative
-------
Did you encounter roadblocks with lack of
knowledge of regulations when
implementing your audit?
Definite
roadblocks
No
roadblocks
28%
^ ^^X^l
Some issues
but no major
issues
64%
Region 2 Healthcare Compliance
Initiative
-------
Did you encounter roadblocks with the
overall time and commitment when
implementing your audit?
Definite
roadblocks
17%
Some issues,
but not major
50%
No
roadblcoks
33%
Region 2 Healthcare Compliance
Initiative
-------
Did you encounter roadblocks interacting
with regulatory agencies
when implementing your audit?
Some issues,
but not major
8%
Definite
roadblocks
6%
No
roadblocks
86%
Region 2 Healthcare Compliance
Initiative
-------
Did you encounter roadblocks with
cooperation of faculty/staff/students
when implementing your audit?
Some issues,
but not
major
25%
Definite
roadblocks
6%
No
roadblocks
69%
Region 2 Healthcare Compliance
Initiative
-------
How much time was required to complete
the correction of all areas of
non-compliance?
More than 60
days but less
than 120 days
26%
Within 60 days
32%
More than 120
days
42%
Region 2 Healthcare Compliance
Initiative
-------
What influenced you to participate in an Audit
Agreement or self-disclosure?
Moral
responsibility
27%
Avoid
enforcement
action
41%
Penalty
reductions
32%
Region 2 Healthcare Compliance
Initiative
-------
How often does your institution typically
audit your formal multi-media
environmental compliance audit?
Once every
three to five
years
25%
Once every
year
62%
Once every
two years
13%
-------
Reported Hospital Audit Cost;
ost of audit is approximately
cost of compliance is approximately
$10,200
Ayerag
$29,3 OC
: cost of compliance without two most
expensive (>$ 100,000) is approximately
$16,600
Region 2 Healthcare Compliance
Initiative
-------
Does your institution have a
formal Environmental
Management System (EMS)?
Region 2 Healthcare Compliance
Initiative
-------
If an EMS is not in place, are you
considering adopting an EMS?
Not
planned
29%
Under
consider-
ation
0%
Planned
71%
Region 2 Healthcare Compliance
Initiative
-------
If an EMS is not in place, what are
the roadblocks?
consideratio
Insufficient
technical
/ resources
/ 52%
Region 2 Healthcare Compliance
Initiative
-------
Does your EMS include a periodic,
systematic review of your facility's
compliance?
No
8%
Region 2 Healthcare Compliance
Initiative
-------
Has your EMS been the basis for
any operating changes beyond
compliance?
Region 2 Healthcare Compliance
Initiative
-------
Did the Compliance Initiative/self-
audit play a role in the decision to
implement an EMS or modify an
existing EMS?
Yes
68%
Region 2 Healthcare Compliance
Initiative
-------
nnvironrnsr.
anagement
System
The Next Step Is To Becom
Sustainable
Region 2 Healthcare Compliance
Initiative
-------
Wh
review
org
policies, plans, procedures and
^chanisms used by an
>n to achieve its environmental
;tives
may already have substantial parts of
an EMS in place
> Your EMS probably doesn't meet the
requirements of a formal standard (e.g.
lT"UU 1 )
J
Region 2 Healthcare Compliance
Initiative
-------
n E
^ f
•nvjronrn&nm
Review
all relevan
-> Target
-> PJ'c
iificant environmental impacts
:es responsibility for environmental
performance with staff performing the activity
Enhances communication
Establishes oversight for documents and records
Helps to maintain compliance
Region 2 Healthcare Compliance
Initiative
-------
J BaisecJ
invoJ
itment and increase
t of top management
f environmental and mission
AJign merit
objecth
Transition of responsibility for managing
environmental programs
Region 2 Healthcare Compliance
Initiative
-------
r
"fern
-> Informa
>es form
EJsec on peo
persoriaJiti
B
le and procedures, not
J
tinual improvement
Region 2 Healthcare Compliance
Initiative
-------
Get senic
Consider
Write
r manag
suppor
e to star
policy statement
from experience
Build a team and work together
Region 2 Healthcare Compliance
Initiative
-------
Health eg
1 Pollution Prevention
Ion Through Environmental
ent Systems (EPA/625/C-05/00
Region 2 Healthcare Compliance
Initiative
-------
•~\ r-*
^cirer;
healthcare faciuti
r1 f
.ricirici
grivi
ge the culture to one in which
ital compliance is a priority,
iimpliance of entire sector;
:hose reached through
ections.
nsure continued compliance by
Region 2 Healthcare Compliance
Initiative
-------
ohn Gorman
212-637-4008
gorman.john@epa.gov
-w.epa.gov/region02/healthcare
Region 2 Healthcare Compliance
Initiative
-------
Hospital
Compliance Seminar
Managing
Underground Storage Tanks
99
-------
ister
-------
AGENDA
EPA Requirements
ank Closure and Site
Assessment.
Contacts
-------
Requirements
Federally Regulated
USTs
-------
What is a Federally Regulated
UST?
V
- Steel Outer Tank
-------
Jontaining petroleum or hazardous
substances
71
it least 1 0 percent underground (tank &
piping)
1 0 gallons or larger
-------
Tanks not regulated bv EPA:
7 arm/residential tanks 1,100 gallons or less
containing motor fuels used for
noncommercial purposes
Tanks storms heating oil for on-site
consumption (NYS DEC requirement
Emergency spill and overfill tanks
-------
Back to the
Requirements
-------
As an owner / operator of underground
storage tanks (USTs), you must make
decisions about UST~
-------
71 0 y s_ril__ p_r D
D_u
-------
After 12/22/98 all federally regulated USTs
are required to have either:
pgraded to protect from
corrosion, spins ana overrnis or
TI Replaced with new USTs thai have
corrosion, spill and overfill,
protection or
TI Closed properly
-------
-------
Spill Protection
-------
All tanks must have an
approved catchment
basin, often called a
"spill bucket," unless the
tank receives product in
quantities less than 25
gallons at a time.
-------
-------
Unless the tank receives 25 gallons at a
time, all tanks must have an overfill
device
Your options are:
oitomatic shutoff device
)verfill alarm
-------
-------
An automatic shutoff
slows down and then
stops the delivery
when the product has
reached a certain level
in the tank. This
device is activated by a
float mechanism.
nil Pipe
Shutoff
Valve
Float
-------
-------
Overfill alarms use probes
to activate an alarm when
the tank is either 90% full
or within 1 minute of being
overfilled.
Gallon 1075
Incht: 975
ODDDCDOD
Automatic Tank Gauge
Over-fill
Alarm
In Tank
Inventory
Probe
Electronics
Housing
Product Lev&l
Float
Water Level
Float
-------
Corrosion Protection
|- f~. *-mtm -—- m-t
• J C
•: i
TIT
-------
If your existing UST is one of these non
corrodible types, your tank meets the
requirement for corrosion protection:
Clad
Jacketed
Sti-P3
Fiberglass
-------
Steel
Inn^r
Tank
I Ir; r.'ll :!
Space
Steel Ouler Tank
5TI ;ippto'-'cd
or rainforcBd laminala
-------
There are three ways to protect your
existing steel tank from corrosion:
athodic protection
ank interior lining
'athodic protection & interior linin
-------
Electrical Isolation
(Bushings)
Dielectric protection
Coating
Cathodic Protection
(Anode)
-------
Before adding cathodic protection, you have
to make sure the UST is structurally "sound"
TT
and has structural integrity.
-------
For USTs buried 10 + years, you have two
only choices to prove that the tank is
structurally sound:
L professional inspection of the tank's
interior.
in alternative assessment allowed by the
regulatory authority.
-------
7i Statistical Method
based on soil sample
TI Remote Video Camera
plus soil analysis
-------
What if the UST is not
"sound"?
An unsound UST must be either repaired and
upgraded or closed.
You must also check for leaks and take
corrective actions (if necessary) to cleanup an
petroleum released to the environment.
-------
Cathodic Protection Types
(1) sacrificial anodes
(2) impressed current
-------
Both of the corrosion protection methods
described in the following slides must be
designed by a "corrosion expert"
A corrosion expert is either:
•A NACE certified "corrosion specialist" or "cathodic
protection specialist"
•A PE with certification or licensing in corrosion control of
buried metal pipes and tanks
-------
Impressed Current
Rectifier
Grade
Soil
Tank
Impres:
Curre
Ano de
Current Path
-------
An impressed
current system
uses a rectifier to
convert alternating
current to direct
current.
Impressed
Curre nt
Anode
Current Path
The UST system is protected because the current
going to the UST system overcomes the corrosion-
causing current normally flowing away from it.
-------
The tank must be tested
within 6 months of the
installation of the system
and every 3 years (in NY
is 1 year) thereafter.
Additionally: the impressed current system
must be checked every 60 days to make sure
it's operating.
-------
A qualified tester does NOT have to be NACE
certified but must demonstrate an understanding of
principles and measurements of common types of
UST tank and piping cathodic protection systems.
-------
-------
A sacrificial
anode system
uses retrofitted
anodes to protect
the tank from
corrosion.
/1
Anode
-------
As with the impressed current system, it
must be designed by a "corrosion expert.'
The system must be tested within 6
months of installation and every 3 years
(in NY is every 1 year) thereafter
-------
Another option is to internally
line the tank.
-------
The Internal Lining Process
-------
-------
-------
he UST is inspected
-------
-------
-------
-------
j inally, the UST
lining must pass
periodic reinspections
'he first takes place
10 years after the
lining is installed and
every 5 years
thereafter
-------
71
Leinspections
require the tank
to be emptied and
purged, before
the interior lining
can be inspected
-------
Another way to protect your tank from
corrosion is to combine cathodic
protection with tank interior lining.
Cathodic
Protection
Internal
Lining
-------
The combined method has advantages
Your USTs receive more corrosion protection,
You are not required to have the interior lining
periodically inspected.
-------
c
-------
Existing piping must be either
Made of, or enclosed in, a
noncorrodible material such as
fiberglass
If made of metal, it must have
cathodic protection
-------
Otherwise, existing piping must be
upgraded or replaced.
-------
After you have completed the a
new installation or upgrade then
must check with local and state
authorities to meet the codes.
-------
-------
-------
-------
-------
-------
Ipgrade existing USTs
eplace with new USTs
lose properly
-------
-------
Jorrosion resistant tank with corrosion
resistant piping and spill/overfill prevention,
you could use tightness testing every 5
years in conjunction with inventory
monitoring.
Or use another leak detection method
-------
ill tanks and piping no later than 1993
f corrosion resistant tank, upgrade leak
detection by 1998 or 10 years after tank is
corrosion resistant - whichever is later
f bare steel tank, upgrade the leak detection
within 10 years after you upgrade the tank
to being corrosion resistant - no later than
2008
-------
nternal
nterstitial
External
ipmg
Inventory Control or
Manual Tank Gauging
Secondary
Containment
with Interstitial
Monitor
Water Table
— Inventory Probe (or
Automatic Tank Gauging /
Ground water
Monitoring
Well
-------
71
71
71
11 methods are required to be certified
enerally by a third party
ational listing is available
-------
71
nventory Monitoring
Statistical Inventory Reconciliation
vlanual Tank Gauging
^ank Tightness Test
Automatic Tank Gauge
-------
)aily measurements of level, sales and
deliveries
[easure product level to closest 1/8"
Calibrated meter (stick)
Water bottom check (monthly)
.econcile records every 30 days (ten
days in NY)
-------
liird party provider
•ize and throughput limits
Variable threshold
Need quality data
71
Very tank specific
-------
Jseful on tanks up to 2000 gallons
"an be used as stand alone on tanks up
to 1000 gallons
Need to take tank out of service every
week for 36 - 54 hours
"ake two readings at beginning and end
to closest 1/8"
Weekly test result and monthly
averages calculated
-------
nil system test
^olumetric
Ton-Volumetric
acuum
racer
-------
Jot a tightness test
/lay not be useful on
manifolded tanks
Jseful for inventory
monitoring
torn test weekly
Out-of-service test vs
continuous ATG
VEEDEfi ROOT £j
I
-------
Jommon with double
wall tanks
/[onitor weekly
Electronic versus
manual
Sampling
Slandpipa
Electronic
Detection
/o\
Inner Tank Wall
•Double-Walled Steel Tank
- Outer Wall
• Inner Wall
Interstitial Space
•Double-Walled FRP Tank
-------
-------
rround water must
always be less than 20
feet from ground
surface
ioils between tank and
well must have
hydraulic conductivity
of not less than 0.01
cm/sec (gravels, or
other permeable
materials)
MONITORING
WELL
PAVEMENT
WATER TABLE
SURFACE
t
STORAGE
TANK
I
FREE PRODUCT LAYER
PRODUCT/WATER CONTACT
WELL SCREEN
PERIMETER OF
TANK
EXCAVATION
-------
_lie site must be
assessed to determine
correct number and
position of wells
A^ells must be sealed
from the surface
MONITORING
WELL
WATER TABLE
SURFACE
PAVEMENT
BACKFILL
X
STORAGE
TANK
FREE PRODUCT LAYER
PRODUCT/WATER CONTACT
WELL SCREEN
PERIMETER OF
TANK
EXCAVATION
-------
Yells must be placed
within excavation or
as close as possible
/ells may be
manually monitored
weekly or
electronically
Teed to detect 1/8" of
free product
MONITORING
WELL
PAVEMENT
BACKFILL
WATER TABLE
SURFACE
t
STORAGE
TANK
FREE PRODUCT LAYER
PRODUCT/WATER CONTACT
WELL SCREEN
PERIMETER OF
TANK
EXCAVATION
-------
Wells clearly marked
and secured
-------
ioils must allow for
vapors to migrate
'roduct must generate
vapors or use tracer
background
contamination must
not interfere with
detecting leaks
-------
iite is assessed to
determine number and
position of wells
-------
Wells must be clearly
marked and secured
-------
ressurized
Auction
-------
-------
Exempt if
iping is sloped to the tank
)nly one check valve and is located at the
pump
•therwise test every three years or wells.
SIR or interstitial
-------
nternal
nterstitial
External
ipmg
Inventory Control or
Manual Tank Gauging
Secondary
Containment
with Interstitial
Monitor
Water Table
— Inventory Probe (or
Automatic Tank Gauging /
Ground water
Monitoring
Well
-------
-------
Temporary Closure
Within 90 days.
!mpty UST
eal off fills
rood for 1 year
-------
Permanent Closure
71
lean and empty UST
-------
Permanent Closure
emove UST or close in place
-------
Permanent Closure
Permanent Closure
71
71
71
onduct site assessment
g© 0
a a p p p
© ©
g g g g n
OO
-------
Site Assessment
Before permanent closure or a change-m-
service is completed, owners and operators
must:
"measure for the presence of a release
where contamination is most likely to
be present at the UST site."
-------
Site Assessment
fYSDEC document: SPOTS #14
loil samples from the bottom of the tank
excavation
oil samples from the sidewalls of the
excavation
71
roundwater if present in the excavation
-------
Site Assessment
Test methods
71
71
71
screenng
D readings
ab analysis
A Method 802 1 and 8260 base neutrals
TARS # 1 values
Alternative values
CLP values
-------
Site Assessment
71
71
7)
71
ictures
ield screening results
rocation of samples
arration of closure, soil conditions, etc
,ab analysis
-------
Site Assessment
71
^or USTs permanently closed before the
Regulations took effect, a site assessment
can be required if the tank is suspected of
posing a threat to human health and the
environment
-------
Site Assessment - Spill Reporting
71
hours of discovery of the spill. Required by
NYSDEC
NYSDEC SPILL HOTLINE NUMBER:
1-800-457-7362
-------
-------
ust be prepared by a licensed P.E. or
Registered Architect and in compliance with
all applicable City, State and Federal
requirements.
-------
71
71
•rate's Regulation
"ire Department's Regulation
bounty's Regulation
-------
nspect motor fuel facilities
at least once every five
years.
nspection focuses on
registration, leak detection,
overfill protection and
corrosion protection.
f a violations are found,
inspection will result in a
Field Citation or and an
Enforcement action.
-------
,an be a referral from local or state agency
(database)
.andom inspections
ector or Media Initiative
-------
Claudia Gutierrez, (212) 637-4945 or via email at
gutierrez.claudia@epa.gov
www. epa. go v/s werust 1
NYSDEC
Region 1 - 631-444-0230, Nassau and Suffolk
Counties
Region 2 - 718-482-4929, New York City
www.dec.state.ny.us
------- |