NAVY REGION NORTHWEST (NRNW)
WASTE ORIGINATOR
WEB-BASED TRAINING
TRAINING CONTENT OUTLINES
Version 0.2
February 15, 2006
Contract No. N00406-05-F-6001
Task #020.0008
Prepared/Submitted by:
Concurrent Technologies Corporation
5780 W. Werner Road
Bremerton, WA98312
DOCUMENT CHANGE TABLEDATE / AUTHOR / CHANGES MADE / VERSION
1/27/06 / DeSilva / Bandrowski / 0.1
2/15/06 / DeSilva / Bandrowski / Includes input from Design Analysis Workshop on 2/9/09 and 2/14/06 / 0.2
TABLE OF CONTENTS
1.0Background
1.1Document
1.2Course Structure
1.3Overall Course Objectives
2.0WASTE Originator: Orientation Content Outline
2.1Training Objectives
2.2Overview
2.3Content
3.0waste originator: WASTE ClasSification
3.1Training Objectives
3.2Overview
3.3Content
3.3.1Solid Waste: Hazardous and Non-hazardous
3.3.2Hazardous Waste Regulatory Bodies
3.3.3Identifying Hazardous Waste
4.0Waste originator: CONTAINERS and labeling
4.1Training Objectives
4.2Overview
4.3Content
4.3.1Containers
4.3.2Compatibility of Wastes
4.3.3Labeling and Lids
5.0Waste originator: Accumulation Areas
5.1Training Objectives
5.2Overview
5.3Content
5.3.1Accumulation
5.3.2Accumulation Areas
5.3.3Accumulation Area Differences
6.0Waste originator: Spill prevention and response
6.1Training Objectives
6.2Overview
6.3Content
6.3.1Storm Water
6.3.2Spill Prevention Best Practices
6.3.3Spill Response Analysis
6.3.4Spill Response Preparedness
7.0Waste originator: Bangor specific
7.1Training Objectives
7.2Overview
7.3Content
7.3.1Major Roles and Responsibilities
7.3.2Bangor Waste Management Process
7.3.3Filling Out Forms and Labels
LIST OF TABLES
Table 1. Course Map
LIST OF ACRONYMS
DoD / Department of DefenseAUL / Authorized Use List
BOSC / Base operating services contractor
CFR / Code of Federal Regulations
DAW / Design Analysis Workshop
DoN / Department of Navy
EPA / Environmental Protection Agency
FEMP / Federal Energy Management Program
HM / Hazardous Material
IWTP / Industrial Waste Treatment Plant
MSDS / Material Safety Data Sheet
NRNW / Navy Region Northwest
POC / Point of Contact
PWC / PublicWorksCenter
RCRA / Resource Conservation and Recovery Act
SAA / Satellite Accumulation Area
SME / Subject Matter Expert
USN / United States Navy
WAC / Washington Administrative Code
WIS / Waste Information Sheet
WRT / Waste Retention and Transfer Facility
Draft Waste Originator WBT –Training Content Outline
FileNet ID: XXXXX version 2
2/15/06
1
1.0Background
NRNW is currently providing Waste Originator Training through instructor-led classroom-based training at each base within the region. Individual bases are responsible for curriculum development, training schedules and logistics, instructor acquisition and qualifications, records management, trainee reminders, and quality assurance.
Inefficiencies adversely impact the region due to lack of available courses and instructors when needed, trainee travel costs and logistics, and trainee time away from the job, as well as the potential for dissemination of inconsistent information across the region and for redundant development efforts.
To provide more effective services to its internal customers, NRNW has a goal to augment the existing instructor-led training program with web-based Waste Originator Training. The development of standardized, modular environmental online training courses that will be disseminated effectively and efficiently will ensure that environmental goals and associated practices and guidelines are commonly understood and shared by active-duty military and civilian personnel throughout the region.
Per Section 2.5.3.3 of the Technical Proposal, the Design task follows the Requirements task and consists of a Design Concept Report, a functional Prototype, Content Outlines, and Storyboards.
1.1Document
This document, Training Content Outlines, delineates the core content that CTC will use in designing and developing the training program.
Per the Technical Proposal,
Upon client review and approval of the Design Concept Report, CTC will work with the design team and Subject Matter Experts (SME) to develop a detailed content outline for each of the lessons. Focusing on the instructional intent of the training, the content outline will not address the presentation of the content, but will include only the technical information that is to be taught in the training. The Content Outline will be based on the learning objectives and course/lesson structure defined in the Design Concept Report and will be presented in an outline format.
The contents of this document are based upon the data collected during an analysis of existing Navy training content, and during Design Analysis Workshops (DAWs) conducted by CTC and attended by the Navy Design Team, as well as email, telephone and in-person communications.
Once reviewed and approved, this document will become the content specification for of the Waste Originator Training Program.
1.2Course Structure
Per the approved Design Concept Report, the Waste Originator Training Program will be organized into separate modules. Five modules will address general EPA RCRA regulations that can be applied to any site, government or non-government, where hazardous waste is produced. An additional module will address Waste Originator practices that are specific to Bangor. The modules are displayed in the following course map.
Table 1. Course Map
Content Modules / AudienceHazardous Waste Management Overview / Any site, government or non-government, where hazardous waste is produced
Waste Classification / Any site, government or non-government, where hazardous waste is produced
Containerization and Labeling / Any site, government or non-government, where hazardous waste is produced
Waste Accumulation / Any site, government or non-government, where hazardous waste is produced
Spill Preparedness and Prevention / Any site, government or non-government, where hazardous waste is produced
BaBangor Waste Originator / Bangor-specific
1.3Overall Course Objectives
The overall goal of the Waste Originator Training Program is that trainees will have an increased awareness of hazardous waste management and spill response procedures relevant to their jobs. To achieve that goal, trainees will be able to demonstrate these general objectives as a result of the training:
- Describe the importance of hazardous waste management to human health and the environment.
- Practice good housekeeping as it relates to hazardous waste management and spill prevention.
- Understand that each individual, regardless of position, is accountable for taking action to properly manage hazardous waste and prevent spills.
2.0WASTE Originator: Orientation Content Outline
2.1Training Objectives
- Describe the basic purpose of RCRA regulations
- Describe the importance of hazardous waste management to the US Navy
- In very general terms, identify how RCRA regulations apply to hazardous waste management at worksites
2.2Overview
The orientation will provide an introduction to RCRA regulations. Upon completion of the Waste Originator Orientation, the trainee should be able to identify how RCRA regulations relate to his/her worksite. This module will open with examples of environmental catastrophes that led to RCRA.
2.3Content
Original Source: Botkin, D.B. & E.A. Keller. 2005. Environmental Science: Earth as a Living Planet. 5th Edition. John Wiley and Sons, New York, NY.
Our environment and human health are dependent upon the proper disposal of hazardous waste. Situations like the well-known horror story of the LoveCanal gave rise to the management of hazardous waste in the United States. Hazardous Waste Management began in 1976 with the passage of the Resource Conservation and Recovery Act (RCRA).
At the heart of RCRA is identification of hazardous wastes and their life cycles. The Act provides guidelines for those who manufacture, transport, and dispose of hazardous waste. This is known as “cradle to grave” management.
Original Source: CFR Titles 40 and 49 and Washington State Department of Ecology Dangerous Waste Regulation, 173-303 WAC
RCRA requires anyone who handles hazardous wasteto receive training. If you are taking this training because it is required by your worksite, you will have complied with a RCRA regulation upon completion. This training will enable you to identify wastes produced in your work area and the hazards of each waste. You will also be able to follow RCRA procedures to ensure that hazardous wastes are safely and properly handled.
3.0waste originator: WASTE ClasSification
3.1Training Objectives
- Define the following terms: solid waste, a reusable item, recyclable, non-hazardous waste, hazardous waste, acutely hazardous waste
- Differentiate between a solid waste and a reusable item
- Provide examples of recyclable materials
- Identify the regulatory bodies that govern hazardous waste designation
- Describe EPA characteristics of hazardous wastes
- Identify EPA listing criteria of hazardous wastes
- Identify Washington DOE regulations
- Use a questioning process to identify hazardous wastes
3.2Overview
Upon completion of the Waste Classification module, the trainee should be able to apply knowledge of RCRA and Washington State Regulations to identify hazardous waste. Under RCRA, waste is designated as hazardous using two different mechanisms:
- listing certain wastes as hazardous
- identifying characteristics that, when present in a waste, make it hazardous.
This module will discuss these designations, as well as WashingtonState regulations. A questioning process to aid the trainee in identifying hazardous wastes will be provided.
3.3Content
Waste is created everyday in your work environment. In order to protect the environment and human heath, RCRA governs the accumulation, transport, and disposal of hazardous waste. Mismanagement of waste can harm human health and the environment, as well as lead to steep fines.
Original Source: State of Oregon, Department of Environmental Quality, Fact Sheet: How to Determine if Your Waste is Hazardous. Last Updated: 10/24/05
3.3.1Solid Waste: Hazardous and Non-hazardous
Waste is anything with no further use and has been or will be thrown away. A solid waste isn’t necessarily a solid material; it can also be a liquid, semi-solid, or contained gas. Wastes can be broadly categorized as either non-hazardous, hazardous, or acutely hazardous.
Original Source: Navy Region Northwest, Bangor Waste Originator Training class handout materials.
3.3.1.1Non-Hazardous Wastes (Exempted Wastes)
Wastes that are not hazardous include recyclables, trash, and sewage. These wastes are exempt from RCRA management as hazardous wastes. Excluded categories of waste generally are not hazardous waste, are regulated under other state and federal programs, or are recycled in ways that do not threaten public health or the environment.
Types / Examples / Proper DisposalRecyclables / Uncontaminated wood, paper, glass, plastic, and metal / If there is not a designated RecyclingCenter at your site, be sure to follow site specific procedures for recycling
Trash / Uncontaminated textiles (clothing, furniture, etc), foods (no liquids) / Refuse dumpster
(No liquids, gases, oil, or chemicals)
Sewage / Beverages, human waste, wash water from cleaning oneself / Never into a storm drain, only sanitary sewage can be discharged in a sanitary sewer
Original Source: Washington Administrative Code (WAC) 173-303-100)
3.3.1.2Hazardous Waste
Hazardous wastes are any solid, liquid, or contained gaseous material for disposal or recycle that poses significant potential harm to human health or environmental quality. Wastes are “hazardous” when they or their containers are disposed of in a quantity or concentration that poses a threat to human health, wildlife, or the environment. They might cause death, injury or illness.
A small group of hazardous wastes are acutely hazardous. These wastes will persist in a hazardous form for several years or more at the disposal site. They present a significant environmental hazard and are toxic to people and wildlife.
If a non-hazardous waste is mixed with any amount of a hazardous waste, the resulting mixture is considered hazardous. Likewise, if a non-hazardous waste is mixed with any amount of acutely hazardous waste, the resulting mixture is considered acutely hazardous.
Original Source: United States Environmental Protection Agency, RCRA Training Module, Introduction to Hazardous Waste Identification (40 CFR Parts 261) September 2005
RCRA defines hazardous waste in two ways: a statutory definition and a regulatory definition.
RCRA statutory definition:
A solid waste, or a combination of solid wastes, which because of its quantity, concentration, or physical, chemical or infectious characteristics may:
(a) cause, or significantly contribute to, an increase in mortality or an increase in serious irreversible, or incapacitating reversible, illness; or
(b) pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, or disposed of, or otherwise managed
RCRA regulatory definition
Uses two different mechanisms:
- Listing certain specific wastes as hazardous
- Identifying characteristics which, when present in a waste, make it hazardous
3.3.2Hazardous Waste Regulatory Bodies
Hazardous waste can be identified in the following ways:
- On EPA HW lists (waste derived from specific and non-specific sources; discarded chemical products)
- Exhibits EPA HW Characteristics of Ignitability, Corrosivity, Reactivity, or Toxicity
- MeetsWashingtonState’s criteria for Persistence, Toxicity, Corrosive Solid or PCB
Original Source: United States Environmental Protection Agency, RCRA Training Module, Introduction to Hazardous Waste Identification (40 CFR Parts 261) September 2005
3.3.2.1EPA Hazardous Waste Listing
Only knowledge of a waste’s origin is needed to determine if it is listed. By comparing any waste to listing descriptions, one can easily determine if the waste is hazardous.
Waste List / Examples / Description / NumberF List
Non-specific Source / Methylene chloride
Xylene
Toluene
Acetone
Cresols
Paints & solvents / Wastes generated from a wide variety of industries and manufacturing processes / F001-F039
K List
Specific Source
(uncommon—one at Bangor) / Spent carbon from the treatment of wastewater containing explosives / Wastes generated from a specific industry and process / K001-K148
U List
Toxic Commercial Chemical Products / Hydrazine
Phenol
Dibutyl phthalate
Methyl isobutyl ketone
(Lab reagents,
Special cleaning agents) / Pure unused chemicals that pose a significant threat to human health or the environment / U001-U411
P List
Acutely Toxic Commercial Chemical Products
(Uncommon-one at Bangor) / Sodium cyanide
Strychnine
Potassium cyanide
beryllium / Pure unused chemicals that possess extremely hazardous properties that make them lethal in very small quantities / P001-P205
Original Source: United States Environmental Protection Agency, RCRA Training Module, Introduction to Hazardous Waste Identification (40 CFR Parts 261) September 2005
3.3.2.2EPA Hazardous Waste Characteristics
When defining hazardous waste characteristics, EPA does not study particular waste streams from specific industries. Instead, EPA asks the question, “What properties or qualities can a waste have that cause that waste to be hazardous?”
Exhibits EPA Hazardous Waste Characteristics (Four Characteristics)
D001 Ignitable / D002 CorrosiveEasy Definition: can readily catch fire and sustain combustion
Examples: paint wastes, solvents
Other info: Most are liquid in form; certain compressed gases and chemicals called oxidizers can also be ignitable; among the most common hazardous wastes
Test method: Flash test / Easy Definition: dissolves metal, other materials or burns the skin
Examples: Acids, Caustics
Other info: among the most common hazardous wastes
Test Method: pH test
D003 Reactive / D004-D043 Toxic
Easy definition: Unstable, may react with water, air, or other chemicals
Examples: organic peroxides, wastes containing cyanides and sulfides / Easy definition:
Poisonous; can harm you when you touch breathe, or swallow it
Examples: heavy metals, pesticides, insecticides, herbicides
Other info: Heavy metals are the main type of hazardous waste in this category. Specific metals are: lead, mercury, silver, selenium, arsenic, barium, cadmium, chromium
Other common toxins are:
BenzeneMethyl ethyl ketone
Original Source: Jim Dye, Meeting at Bangor, Dec. 27, 2005
Note: Many toxic hazardous wastes contain heavy metals. On the D004-D043 Toxicity Characteristic list, eight of the hazardous wastes are heavy metals: arsenic, barium, cadmium, chromium, lead, mercury, selenium, and silver. The others are pesticides and solvents, and with the exception of benzene and methyl ethyl ketone, are uncommon. The heavy metals are often found in the paint of older materials, and when paint is removed, the waste paint chips must be disposed of as hazardous wastes.
Original Source: WashingtonState Legislature, WAC Chapter 173-303, Dangerous Waste Regulations
3.3.2.3WashingtonState Hazardous Waste Classification
Original Source: (Section: Washington State Dangerous Waste Regulations)
WPO1 and WPO2: are assigned to wastes that contain halogenated organic compounds in combined concentration greater than 100 ppm
WP03: is assigned to waste that contains certain polycyclic aromatic hydrocarbons in combined concentration greater than 1%
WT01 & WT02: are assigned to certain toxic wastes
WSC2: is assigned to solids and semi-solids that exhibit a pH less than or equal to 2 or greater than or equal to 12.5
WPB: is assigned to discarded transformers, capacitors or bushings contaminated with PCBs between 2 and 50 ppm, and to waste generated from salvaging, rebuilding or discarding 2 - 50 ppm transformers, capacitors or bushings
WP01-WP03: Persistent Hazardous Wastes / WT01 & WT02: Toxic Hazardous WastesExamples: Chlorinated cleaning solvents (carburetor cleaner, old paint stripper, methylene chloride) / Examples: Wash waters, spent solvents, batteries, paints, coatings and sealing compounds.
WSC2: Corrosive Solids / WPCB
Examples: Acid soaked rags, Acid clean up / Examples: discarded transformers, capacitors or bushings contaminated with PCBs between 2 and 50 ppm
Original Source: United States Environmental Protection Agency, RCRA Training Module, Introduction to Hazardous Waste Identification (40 CFR Parts 261) September 2005
3.3.3IdentifyingHazardous Waste
Waste designation is the process used to decide if a waste is hazardous. Ideally you should acquire a waste designation from your site’s environmental department before you create any waste stream. However, if you create a waste before it has been designated by the environmental department, contact your site’s waste manager for guidance.
Who is responsible for designation?
Legally the generator is always responsible for waste designation. A “generator” is any person, by site, whose act or process produces dangerous waste or whose act causes a dangerous waste to become subject to regulation.This often means the person at the highest level of responsibility; currently, the Generator is the Commander Navy Region Northwest. While it is the environmental department’s responsibility to give a waste an exact designation, you should be able to differentiate between non-hazardous wastes, hazardous, and acutely hazardous wastes.
Original Source: United States Environmental Protection Agency, RCRA Training Module, Introduction to Hazardous Waste Identification (40 CFR Parts 261) September 2005