Welcome to Federal Laboratories Environmental Compliance Training Course.
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Course Navigation
Slide 4 - Course Navigation
Here are some things you should know before beginning this course:
Click the Course Navigation tab in the upper right to learn how to navigate through the course.
Move your cursor over any underlined word to see its definition, or click on a link to access more information online.
You can click Glossary for a glossary of terms, and References to links to many of the documents referenced in the course.
Topics are presented as individual sections, so you may navigate to the desired topic without having to take the entire course. Scroll through the outline and choose the regulatory topic you would like to learn more about.
Each section will proceed with narration unless the ‘pause’ button is selected. Use the ‘play’ button to restart.
Select the Next button at the bottom of the screen to begin.
Slide 5 - Welcome
Welcome to Environmental Compliance for Federal Laboratories. This course is sponsored by the U.S. EPA’s Federal Facilities Enforcement Office (FFEO). Among its responsibilities, FFEO and its Federal Facilities Program Managers around the country track federal facility compliance with environmental laws, regulations, and Executive Orders, provides compliance assistance, and, when appropriate and necessary, enforce against violators.
This training is not intended as a complete course on every environmental regulatory requirement that laboratory facilities may encounter. The course highlights common problems and violations identified by EPA inspectors, and offers suggestions on how to comply. Environmental management systems and pollution prevention practices are also highlighted to help you address your environmental compliance challenges.
Introduction: Why should federal laboratories take this training?
Slide 7 - Why should federal laboratories take this training?
Let’s review why federal laboratories should take this training.
Federal laboratories, as well as all federal agencies, are required to comply with environmental laws governing air and water pollution and hazardous waste – these include federal, state and local requirements. Several Presidential Executive Orders have underscored environmental compliance requirements and have also focused attention on proactive ways for the U.S. government to meet environmental goals and institute environmentally sustainable practices.
Laboratory management and staff can help their facility maintain compliance by being aware of and following all applicable environmental requirements, and helping to institute good stewardship practices. Most laboratories, like many other federal facilities, are also required by Executive Order to have Environmental Management Systems (EMS) under EO 13423.
EMSs and pollution prevention programs are tools to help facilities comply with their regulatory requirements.
This course illustrates some ways facilities have used these tools to help manage their compliance requirements, minimize their impact on the environment, and improve environmental stewardship.
Why is this training so important for federal laboratories? Environmental management issues associated with labs present a unique challenge because lab operations differ from the processes found at manufacturing and service entities. At laboratories, a large variety of substances are used in small quantities. There is also high variability in operations and the possibility of creating new substances.
FedCenter - Facility Regulatory Tour: Laboratories
Slide 8 - Objectives
On completing this course, you should be able to:
This course WILL NOT:
Please consult your local regulators and their guidance materials to learn about any additional requirements that may be applicable to your facility.
Slide 9 - Objectives
In order to accomplish the course objectives, we will start with a summary of relevant Executive Orders, then introduce Environmental Management Systems, or EMS, and Pollution Prevention, or P2. Then we will address the individual regulatory topics, specifically hazardous and universal waste, waste water, air releases, toxic chemical management, underground storage tanks, bulk oil storage, and underground injection.
Other requirements are briefly mentioned, and some are enforced by other regulatory agencies such as OSHA.
Each regulatory topic is a separate section in this course. Remember that you may navigate to different sections using the outline on the left.
Section I: Executive Orders, EMS & P2
Slide 11 - Summary of Relevant Executive Orders
Here we introduce the two primary Executive Orders that pertain to environmental compliance and environmental stewardship at federal facilities. The following screens will go into each of these Executive Orders in more detail.
To learn more about Executive Orders 12088 and 13423, please visit:
FedCenter: Executive Order 12088
FedCenter: Executive Order 13423
Slide 12 - Executive Order 12088: Federal Compliance with Pollution Control Standards
Executive Order 12088, Federal Compliance and Pollution Control Standards, makes each Federal agency responsible for complying with environmental laws. Those specifically listed in the Executive Order are:
These are all federal environmental laws, but remember that federal facilities must also comply with state and local environmental regulations.
Slide 13 - Executive Order 13423: Strengthening Federal Environmental, Energy and Transportation Management
Executive Order 13423 is titled “Strengthening Federal Environmental, Energy, and Transportation Management.” It requires federal facilities to use EMS as the primary management approach for managing the environmental aspects of federal agencies, including laboratory operations.
Under this EO, goals should be established for energy efficiency and greenhouse gas emissions, renewable energy, water consumption, sustainable environmental practices in acquisition, hazardous chemical use and waste, cost-effective waste prevention and recycling programs, high performance and sustainable buildings, petroleum consumption by motor vehicle fleets, and environmentally sound practices when purchasing, maintaining, and disposing of electronics.
Slide 14 - Environmental Management System (EMS) Introducion
The importance of EO 13423 is that it requires you to use an Environmental Management System, so we will now learn more about them. EMSs are a set of documented processes and practices that enable an organization to reduce its environmental impacts, increase its operating efficiency, and comply with regulatory and other requirements.
Slide 15 - Environmental Management System (EMS)
Introduction
The basic model for an EMS is the five-step process shown here. This course presents the highlights of an EMS. There are many other sources of information available to you if you need to develop or implement one.
Click the dots to learn more about each element of an EMS.
Policy
Establishing a Policy is the first step in implementing an EMS. An EMS Policy describes the lab organization’s commitment to protecting the environment. Use this policy as a framework for planning and implementation. You should already have an environmental policy in place at your facility. For this reason we will not be discussing EMS Policy during this training, and will be going into detail only on the other four elements of an EMS.
Planning
The second step is planning. The planning stage identifies the environmental activities, aspects, and significant impacts at the facility; formulates objectives in line with the policy; plans actions to achieve these objectives; and ensures that the plan reflects compliance with Federal, state, tribal and local regulations. Your facility’s plan covers three specific components:
Here are two examples of common activities at federal research and analytical laboratories and their associated aspects and impacts:
Implementation & Control
The third step is Implementation & Control, which covers a number of specific components of your EMS:
Checking & Corrective Action
The fourth step, Checking and Corrective Action, has five components:
Management Review
Management Review is the final step in the cycle and a critical one.
This element ensures periodic review of the EMS by senior decision-makers with authority over policy and resources. Reviews are critical to evaluating overall program effectiveness and instituting improvements where needed.
Objectives are reviewed annually by management to determine whether the lab is meeting them, and new targets or new programs are established as needed.
Note that an EMS is a cycle, and as such, it embodies the concept of continual improvement.
Slide 16 - Environmental Management System (EMS) in Action
Introduction
Now we’ll take an in-depth look at each of the EMS elements. As mentioned earlier, we will not be discussing the “Policy” element of the EMS in this training, although it is very important. The policy establishes the environmental vision of an organization.
Select each item to learn more.
Planning
The Planning element has 3 basic components: determining environmental aspects and impacts: legal and other requirements; and objectives, targets and environmental management programs.
It is suggested that you involve all relevant personnel at this stage and conduct a room-by-room analysis to develop a comprehensive list of environmental activities, aspects and impacts.
Once the environmental aspects and impacts are identified and significance is determined, you must have a way to identify and keep track of the legal requirements that apply to them. Next, you want to marry environmental policy and significant aspects with specific objectives, targets and associated environmental management programs. This includes identifying specific actions, schedules for those actions, and metrics to determine progress.
Roles must be identified for Environmental Management Programs as well as how the programs will be accomplished. This will be discussed further on the next screen.
Implementation & Control
For Implementation and Control, we describe six components.
The first is to define roles and responsibilities and provide resources to implement the EMS.
Second, personnel must receive appropriate training.
And third, communication pertains to both internal and external communication about environmental issues.
Documentation of the EMS should convey the relationship between its various components. Documentation and document control procedures are especially useful in managing changes that might affect regulatory requirements, (for example, RCRA status), or lab management, such as adjustments to routine operations and maintenance or increased chemical inventories.
The purpose of Operational Controls is to ensure that performance and actions meet the objectives and targets and follow the associated management plans.
Also under Implementation and Control are the lab’s processes needed to respond to abnormal operating conditions, accidents or emergencies and prevent those circumstances where possible.
Checking & Corrective Action
The next major element of the EMS is Checking and Corrective Action, and we will describe the 5 components. Because you cannot manage what you don’t measure, the first step is to monitor the facility’s operations and activities that significantly impact the environment. Evaluation compares the organization’s environmental performance against indicators of compliance, including compliance with regulations and metrics established in Environmental Management Plans.
When nonconforming problems such as a regulatory violation are identified, the facility must have a process in place to learn the cause and take corrective and preventive action, and document these actions.
Next, the EMS calls for maintenance of appropriate records to demonstrate that the facility is properly following the requirements of their EMS.
And periodically, the EMS itself is audited to make certain it is being used effectively. The audit findings will be covered later as part of management review.
Management Review
The final step in the EMS process is to have top management review the EMS, document the review, and take actions to make improvements. This step is critical to the success of any EMS because it ensures senior decision makers are aware of and support any changes that might be needed to ensure that the lab is in compliance and in line with policy and goals.
In the spirit of continual improvement, this is not the final step, because you will then return to the planning element to revise and deploy any needed changes and then proceed with the cycle again.
Slide 17 - Environmental Management System (EMS) in Action
As you progress through the topic-specific sections of the course, you will learn about how EMS will help your lab achieve or maintain compliance in, for example, hazardous waste management, wastewater management and oil storage.
The subset of EMS components you see on this screen will be discussed in more detail as they relate to each set of common violations and problems for these regulatory topics, because what you do for these components of the EMS may differ for different topic areas.
Slide 18 - Pollution Prevention (P2) Introduction
Now that we’ve looked at EMS, let’s discuss pollution prevention, or P2. P2 refers to practices that reduce or eliminate the amount and/or toxicity of pollutants which would have entered any waste stream or that would have been released into the environment prior to recycling, treatment, or disposal.
P2 applies not only to all types of waste, but also to releases to air, water, and land.
Preventing pollution can help you comply with environmental regulations. For example, if you don’t create a hazardous waste in the first place, your facility will not be subject to associated legal requirements. And reducing the quantity or toxicity of releases may help you get below regulatory or reporting thresholds.
The commitment to prevent pollution is a required part of your EMS policy. Executive Order 13423 relates to P2 as it sets goals for energy efficiency, acquisition, renewable energy, toxics reductions, recycling, renewable energy, sustainable buildings, electronics stewardship, fleets, and water conservation.
Pollution prevention is the preferred method of environmental protection!
More info about pollution prevention at federal facilities
Slide 19 - Environmental Protection Hierarchy
Introduction
Select each segment of the pyramid to learn more about P2.
Prevention & Reduction
Pollution prevention means practices that reduce or eliminate the creation of pollutants at the source through:
Recycling and Reuse
Pollution that cannot be prevented should be reused or recycled in an environmentally safe manner, whenever feasible.
Treatment
Pollution that cannot be prevented or recycled should be treated in an environmentally safe manner whenever feasible.
Disposal
Disposal or other release into the environment should be employed only as a last resort and should be conducted in an environmentally safe manner, and with the proper permits, if required.
Slide 20 - Summary of EOs, EMS and P2
We have presented a summary of relevant executive orders and introduced environmental management systems and pollution prevention. Now let’s take a moment to check your knowledge.
Check Your Knowledge 1 - Question 1
EO 13423 requires federal labs to implement an EMS. What are some of the goals of the EO?
Select the correct answer.
a) Improve energy efficiencyThe answer is D. Improving energy efficiency, reducing hazardous chemical use and waste, and reducing water consumption are all goals of an EMS as per the Executive Order.
Check Your Knowledge 1 - Question 2
Executive Order 12088 requires federal facilities to comply with all pollution control laws and regulations. Which pollution control standards are explicitly stated in this Executive Order?
Select the correct answer.
a) Clean Water Act and Federal Water Pollution Control ActThe answer is E. Both CWA, FWPCA and TSCA are named in the Executive Order as statutes to which federal facilities must comply.
Check Your Knowledge 1 - Question 3
Why is source reduction preferred over recycling as an environmental management approach?
Select your answer.
a) Recycling requires reprocessing to turn waste into usable materialThe answer is D. Each of these statements explains why source reduction is preferred over recycling.
Section II: Handling Hazardous and Other Waste
Slide 22 - Handling Hazardous and Other Waste
We now turn to common problems and violations in various environmental areas at laboratories. We’ll start with hazardous and other waste.
The general format for this section will be a presentation of common problems and violations, followed by a brief summary of the regulatory requirements. Then we’ll go into how your EMS fits in, and how pollution prevention can help.
Slide 23 - Common Problems and Violations: Hazardous Waste
We’ll now discuss some of the common problems and violations pertaining to hazardous waste.
EPA inspectors have noted a common problem for federal laboratories as the failure to determine or characterize its waste as hazardous, either by testing it or by applying knowledge about the waste.
Some common mistakes include:
EPA’s definition of solid and hazardous waste
Slide 24 - Is My Waste a Hazardous Waste?
Let’s look at a good method to help minimize potential problems. When making your hazardous waste determinations, go through your facility on a lab-by-lab or process-by-process basis. You should evaluate all materials: products, by-products, co-products, reactants, spent materials, recyclables, outdated chemicals, etc.
Next, answer the series of questions on this screen to help determine if the waste is hazardous. It is best to document your determinations of materials that are and are not hazardous wastes. This will help you explain your decisions to an inspector, if asked.
This screen offers some references to help you determine if a waste is hazardous. You do not want to define a non-hazardous waste as hazardous, as this will increase your waste management responsibilities, costs and liability. Nor do you want to define a hazardous waste as non-hazardous, as this will cause you to be out of compliance.
According to RCRA, so-called “listed” wastes are hazardous wastes from non-specific sources, and are associated with an EPA hazardous waste number.
Characteristic wastes are: ignitable, corrosive, reactive, toxic, or acutely hazardous.
Now that we have reviewed waste characterization, let’s review some common problems that relate to hazardous waste generator status.
Slide 25 - Common Problems and Violations: Generator Status
Generator status is another area where violations occur. This may include:
An example of this problem is when a facility under or over-estimates their generation, and therefore incorrectly classifies itself. Being conservative and classifying your facility as a Large Quantity Generator when it is not, does not benefit the facility, as it is then subject to more stringent regulations and must file biennial reports. And it may redirect attention from large generators, which require more frequent inspection.
It can be a challenge when a facility fluctuates between two classifications due to changing waste generation. In this case, you might want to consider identifying the activities for which waste generation fluctuates and trying to reduce that waste stream.
Large Quantity Generators and Small Quantity Generators, also known as LQGs and SQGs respectively, are required to have a contingency plan for responding to emergencies. However, LQGs are required to have detailed, written plans while SQGs are not. These two designations will be discussed on the next screen.
Slide 26 - What Size Hazardous Waste Generator Am I?
This shows the criteria for each of the generator categories. Use this information to avoid misclassifying facility size… a common problem.
LQGs and SQGs are required to obtain a generator ID number. CESQGs do not need to obtain an EPA ID number because they are exempt from the notification requirements in RCRA. However, authorized states may still require one.
Acute hazardous waste includes substances such as arsenic oxide, calcium cyanide, fluorine, nitroglycerine, and sodium azide. These are often referred to as “P-listed wastes.” The presence of acute hazardous waste is often what tips a laboratory from a SQG to a LQG.
More about Hazardous Waste Generator size and classification
Summary of Federal requirements for each type of generator
Slide 27 - Commone Problems and Violations: Accumulation and Storage
Another challenge for federal laboratories is correct management of accumulation and storage of hazardous waste. During lab inspections, EPA has observed many storage practices that could cause concerns. Chemicals stored for an inappropriately long time may become unstable and explode. For example, picric acid, a chemical found in many laboratories, dries and forms crystals that may explode when the container is handled.
A second problem is the placement of reactive waste chemicals placed close together. If they were to mix, these chemicals could cause explosions and start fires.
Common problems for hazardous waste storage are:
It is important to understand the difference between a hazardous waste storage area and a hazardous waste satellite accumulation area. We will review some of the differences on the following screens.
Info about hazardous waste storage at federal labs
Slide 28 - Accumulation and Storage Requirements
The requirements for the two types of storage areas are different, so you need to be sure you are placing your waste in the proper storage area and the storage and accumulation areas are in compliance with their associated regulations. A satellite accumulation area can accumulate multiple waste streams but must:
Note: When full or moved, the container must be dated.
More information on Satellite Accumulation Areas
Slide 29 - Accumulation and Storage Requirements (continued)
Hazardous waste storage areas are locations where waste is brought after accumulating in an SAA. Requirements for hazardous waste storage areas include:
Slide 30 - Common Problems and Violations: Disposal of Waste
Now we continue with disposal problems and violations having to do with hazardous waste.
These include:
We will talk more about land disposal restrictions on the following screen.
Slide 31 - Documentation Requirements for the Disposal of Waste
Restricted waste is hazardous waste that is prohibited from land disposal if applicable treatment standards are not met. When disposing of waste that is also classified as a “restricted waste”, LDR notification is required to accompany the manifest. (40 CFR 268) The minimum requirements for a restricted waste include waste analysis, recordkeeping, and notification. Restricted wastes are subject to treatment standards designed to reduce the toxicity of the waste or reduce the possibility that the hazardous constituents will migrate.
Keep in mind the following:
Another common problem for federal laboratories is documentation requirements for training and inadequate training. Let’s review those requirements next.
More info about Land Disposal Restrictions
Slide 32 - Common Problems and Violations: Training Requirements
Problems in the area of Training are typically due to inadequate training, poor documentation, training not done and reviewed in a timely manner, or components of required training not completed.
Common problems related to training requirements include inadequate training.
A training program should:
Slide 33 - Hazardous Waste Training Requirements
Training is required for LQGs and SQGs, as well as for those who work in a central accumulation area or who move hazardous waste from an SAA to a central accumulation area. RCRA regulations do not require training of personnel who work only in SAAs.
Formal training is not required for CESQGs or those that only work in a SAA, but is advisable for good environmental management. For LQGs and SQGs, (40 CFR Section 265.16) training requirements are:
Slide 34 - Common Problems and Violations: Contingency Planning for LGQs
Other common problems for LQGs relate to the hazardous waste contingency plan.
These include:
Note that the local emergency service provider may be the military. For example, if the lab is located on a military base, military personnel would get a copy of the contingency plan.
Slide 35 - Hazardous Waste Contingency Plans
An LQG must have a contingency plan for the facility according to 40 CFR 264.227 and 265 Subpart D. The contingency plan must be designed to minimize hazards to human health or the environment from fires, explosions, or any unplanned sudden or non-sudden release of hazardous waste or hazardous waste constituents to air, soil, or surface water.
The provisions of the plan must be carried out immediately, whenever there is a fire, explosion, or release of hazardous waste or hazardous waste constituents which could threaten human health or the environment.
Now that we’ve covered handling hazardous waste we will go on to a knowledge check.
Check Your Knowledge 2 - Question 1
Plans to improve laboratory staff’s knowledge of hazardous waste in the lab should include training. A laboratory hazardous waste training program should include all of the following except:
Select all that apply.
a) Ensure employees are prepared to keep the facility in compliance
b) Be taught by a manager trained in EMS management procedures
c) Ensure employees can respond to emergencies
d) Training for those working in a Satellite Accumulation Area
B and D are the correct answers. A RCRA training program should be taught by someone trained in hazardous waste management procedures, not necessarily in EMS procedures (although that certainly would be helpful). Training is only required for those moving waste from a SAA to a central accumulation area, but not for those strictly working in a SAA. It is correct that a RCRA training program should prepare personnel to keep the facility in compliance as well as to respond to emergencies.
Check Your Knowledge 2 - Question 2
A laboratory technician has just added some hazardous waste to the appropriate container at the satellite accumulation area and it is now full. What should the technician’s next step be?
Select your answer.
a) Let the lab supervisor know so they can label the container correctly
b) Date and move the container to another side of the lab
c) Leave for the cleaning people to put in the appropriate waste container
d) Label the hazardous waste container with the date the container was filled and then notify the Environmental Manager who will move the hazardous waste to the hazardous waste storage area.
D is the correct answer. The container must be immediately labeled by whoever filled it, and an authorized person must move the container from a satellite accumulation area to a hazardous waste storage area.
Check Your Knowledge 2 - Question 3
Complete the statement, Satellite Accumulation Areas:
Select all that apply.
a) Can store multiple waste streams
b) Require weekly inspection
c) Must be at or near the point of generation
d) Do not need labels
e) Have an accumulation limit of 55 gallons for all types of hazardous waste
A and C are the correct answers. SAAs can store multiple waste streams and must be at or near the point of generation.
Check Your Knowledge 2 - Question 4
Conditionally exempt small quantity generators (CESQGs) are required to obtain EPA identification (ID) numbers.
Select your answer.
a) True
b) False
False is the correct answer. CESQGs do not need to obtain EPA ID numbers, because they are exempt from the notification requirements in RCRA Section 3010 (40 CFR Section 261.5(b)). However, authorized states may have more stringent requirements for obtaining an ID number than the federal program.
Check Your Knowledge 2 - Question 5
Your federal laboratory has two locations. The main office and lab is in Massachusetts and the other laboratory is in Connecticut. Which of the following statements is true about your generator status and the requirements your lab is subject to?
Select your answer.
a) As a federal laboratory you are subject only to federal requirements
b) Since the main office is in Massachusetts, you are subject to Massachusetts requirements only
c) Since the main office is in Massachusetts, you are subject to Massachusetts requirements and federal requirements
d) Your laboratory is subject to the state requirements for both Massachusetts and Connecticut and federal requirements
D is the correct answer. Each federal facility is subject to all relevant federal and state requirements in their locality.
Slide 37 - Using EMS to Improve your Hazardous Waste Management
Introduction
We’ve completed a review of some common problems regarding hazardous waste. Now we’ll highlight some of the ways that your EMS can help you improve hazardous waste management at your lab.
Select each item to learn how your EMS provides a framework to help you address these problems and violations.
Planning
For Environmental Aspects and Impacts, you must identify all environmental activities, aspects and impacts associated with your waste streams, satellite accumulation areas, and storage areas at the lab. Involve all relevant personnel who deal with known or potential hazardous waste.
All routine and non-routine activities need to be considered, both inside and outside of the lab. Gather baseline data for waste streams and other relevant metrics. Then periodically check for new waste streams and changes to existing waste streams.
Planning should involve reviewing and understanding all applicable federal, state and local regulations and requirements based on what your generator status is, what waste streams are hazardous waste, and what new activities may be covered by these regulations. Make sure staff are aware of all legal requirements and obligations and that there is a process in place to identify new or changed regulatory requirements.
Here we discuss gathering information, so that you can establish objectives and goals for hazardous waste management. Objectives and targets are related to your policy, which includes compliance, pollution prevention, and continual improvement.
You should:
Implementation & Control
For the Implementation and Control components of your EMS, we outline some considerations for hazardous waste management.
Beyond providing general hazardous materials training, incorporate hazardous waste management topics into other related training courses. Staff and managers need to be trained to recognize, properly manage, and dispose of hazardous waste.
Required training must be documented. This can be particularly important for laboratories with high turnover, such as those with visiting postdoctoral students or research fellows. Such labs may choose to integrate EMS training into basic orientation and introductory training programs for all incoming personnel.
Operational controls procedures are especially useful in managing operational changes that might affect your regulatory requirements (for example, RCRA status) or facility management, such as adjustments to routine operations and maintenance or increased chemical inventories.
EMS activities include developing procedures that ensure proper hazardous waste management practices and using best practices suggested by EPA inspectors. These best practices are, for example, documenting hazardous waste determination efforts, not including excess packaging or over pack material as hazardous waste, and documenting your monthly hazardous waste generation rates.
RCRA generator status is based on monthly generation and accumulation rates (unless state requirements are more stringent). Ensure that operational controls are kept current and that new procedures are developed if needed.
Checking & Corrective Action
Here are ways that you can help improve hazardous waste management through the Checking and Corrective Action components of your EMS. In this step you check that the system is working correctly to address a change, not that there was a change. We discuss only the component regarding “Evaluation of Compliance.”
Perform periodic compliance audits and identify and address areas of noncompliance. Your EMS then needs to be reviewed to determine actions to address root causes. Determine if there have been changes at the lab and that the EMS reflects those changes. For example, does the disposal method for a waste stream need to change and are there regulatory implications for this change? Is this reflected in the EMS? Another example is reviewing hazardous waste generator status.
If facility generator status fluctuates, re-evaluate hazardous waste generation. Can waste generation and disposal be made more uniform (for example, avoid spring cleaning). Lastly, communicate the results of compliance evaluations to build awareness of hazardous waste regulatory commitments.
It is important to conduct a periodic audit of your activities to ensure the EMS is performing as expected and that all hazardous waste activities are compliant, including inspections of waste storage areas.
Management Review For all of the activities performed under your EMS, management review is an important step, which ensures that appropriate decisions can be made and changes enacted if needed.
You will want to present the results of hazardous waste monitoring and measurement efforts including audit results to management, keep management updated on EMS responsibilities and the resources needed to achieve objectives and targets, suggest and solicit recommendations for improving performance and achieving objectives and targets, and ensure that management acts on and supports planned changes or new programs.
Be sure to let managers know of the penalties that may be associated with environmental noncompliance at the lab. Sharing information about various activities, practices or accidents may help to identify common problems which can be corrected throughout the lab.
Slide 38 - Using P2 to Improve your Hazardous Waste Management
Introduction
These are some ways you can use P2 to improve your hazardous waste management.
Click each item to learn more.
Reduce amount of hazardous materials entering the lab
One way is to reduce the amount of hazardous materials entering the facility. When preparing a new testing protocol consider the kinds and amounts of waste generated and determine how they can be reduced or eliminated by, or by changing purchasing practices.
Prior to the start of a research effort, there should be a plan made detailing the expected purchases and uses of hazardous materials and the expected wastes that will be generated. Buy chemicals in small quantities to assure inventory will be used before it expires or deteriorates. The facility may also want to develop a procedure for inspecting the lab prior to the start of a research effort and after the end of the research effort to make sure there are no orphan containers or wastes that need to be disposed.
It is also efficient to share materials that are used to minimize what needs to be purchased or disposed. Of course it is not always possible to share chemicals because individual labs often have separate funding streams, but that doesn’t mean it won’t work in some cases. Some of these practices will be a part of your EMS, as an EMS includes a commitment to prevent pollution.
Reduce use of hazardous materials in the lab
To continue in this theme, reducing the use of hazardous materials in your procedures and experiments will result in reduced waste. It can be effective to substitute less toxic chemicals or to perform experiments in micro-scale.
Reduce generation of hazardous waste leaving the lab
Consider reducing the generation of hazardous waste by decreasing the use of cleaning solvents by reusing solvent or using less to begin with. Avoid accidental creation of hazardous waste by segregating hazardous waste from nonhazardous waste. Include steps to neutralize hazardous materials or reduce toxicity. It is understood that prescribed scientific methodology may not allow for the reuse of solvent or the use of an alternative substance.
Facilities with multiple labs should also explore if there is a mechanism whereby each lab pays for its own disposal costs. This can provide an incentive to reduce the generation of waste at its source.
It can also be effective to take measures to reduce the toxicity of materials before they leave the lab.
Note that in general, if you add even a very small amount of hazardous waste to a non-hazardous waste, all of the waste becomes a hazardous waste. This can easily bump you up to a different generator status and increase your waste disposal costs.
When neutralizing waste to reduce toxicity, note that “neutralize” does not mean “treat.” Treatment by a facility not ‘permitted’ for treatment is illegal and considered a violation.
Slide 39 - Common Problems and Violations: Universal Waste
Now let’s move on to a specific type of hazardous waste: Universal Waste.
Universal Wastes are specific types of hazardous waste and fall into four categories: batteries, pesticides, lamps and fluorescent bulbs, and mercury-containing equipment such as thermostats. Such waste is often mismanaged at laboratories and other facilities, specifically regarding improper collection, storage and/or disposal.
Sometimes it is not known if a lab is a Small Quantity Handler or a Large Quantity Handler of Universal Waste. When this is the case, personnel may not receive required Universal Waste training.
Smaller batteries and fluorescent light bulbs may be discarded in the trash.
When collecting Universal Waste, accumulation times may exceed 1 year from the date the Universal Waste was generated, collection containers may be labeled incorrectly, and collection containers may be open, not be structurally sound, or not be compatible with the UW.
Slide 40 - Does My Facility Generate Universal Waste?
Ordinary solid waste (or trash), and medical waste are also issues at labs, but for brevity we are only going to cover Universal Waste here. Medical waste is regulated by OSHA at the Federal level, although some states regulate it within their environmental regulations and may include animal and not just human pathological waste.
EPA’s Universal Waste regulations streamline hazardous waste management standards for federally designated “Universal Wastes,” which include:
Slide 41 - How Do I Manage Universal Waste Correctly?
There are specific requirements for handlers, transporters, and destination facilities handling Universal Waste. Labs would most likely only be handlers. You will need to determine if you are a small quantity or large quantity handler to be sure of your requirements.
Many of the requirements are the same, such as training and labeling of containers, but a few things are different, such as whether or not you need a manifest and how much waste you are allowed to accumulate on site before you ship it off.
There are requirements for training personnel, and in addition, you must store Universal Waste in closed containers compatible with the waste, either date the containers or date the individual batteries, lamps, etc., and label the containers to indicate contents.
Do not send or take Universal Waste to any location other than a permitted Universal Waste handler or destination facility.
Slide 42 - Using EMS to Improve your Universal Waste Management
Introduction
Now let’s look at ways your EMS can help improve your Universal Waste management practices.
Select each item to learn how it can help address common problems and violations.
Planning
These are the Planning components of the EMS, specifically Environmental Aspects and Impacts, Legal and Other Requirements, and Objectives and Targets, tailored to Universal Waste-related activities.
Gather baseline data for Universal Waste streams and other applicable metrics.
Involve all personnel who use or collect Universal Waste (e.g., lab technicians, janitors).
Keep the activities and aspects list up-to-date by periodically checking for new waste streams and changes to existing waste streams.
There are also considerations for Legal requirements and setting Objectives and Targets pertinent to Universal Waste management.
Make sure staff are aware of all legal requirements and obligations. Develop your objectives and targets from information you have collected regarding Universal Waste. Identify actions to take and environmental management programs that will achieve your targets.
Implementation & Control
These are the Implementation and Control components and activities relevant to Universal Waste. Because Universal Wastes are likely to be found throughout the laboratory and handled by so many different people, it is especially important to incorporate training on this subject into general lab training courses.
Operational controls should include establishing storage areas separate from other hazardous waste storage areas, because the Universal Waste rules differ from other hazardous waste management standards.
Checking & Corrective Action
For Checking and Corrective Action, there are some particular considerations regarding compliance management for Universal Waste storage and labeling, such as how long the Universal Waste has been on site, sealing and labeling containers storing Universal Waste correctly, and writing the date on the container or materials.
Any time a regulatory violation is identified from an internal or external audit or inspection, the EMS requires corrective and preventive actions be implemented and documented.
Management Review
Management Review is a critical opportunity to present and discuss results and next steps. The purpose of the review is to ensure the continuing suitability, adequacy and effectiveness of the EMS. It is also important to let managers know about the penalties that may be associated with environmental noncompliance at the lab.
The management review process is a direct reflection of the commitment of your organization to continual improvement. Management buy-in is critical to making any changes to your EMS and to implementing them so that you can achieve your ultimate goals. Sharing information about various activities, practices or incidents may help to identify common problems which can then be corrected throughout the lab.
Slide 43 - Using P2 to Improve your Universal Waste Management
Now let’s return to pollution prevention and offer ideas of ways to reduce the amount of Universal Waste you generate.
Some suggestions include:
Batteries, bulbs, and mercury are emphasized over waste pesticides because these are the Universal Wastes that are more commonly found in laboratory environments.
Back to TopCheck Your Knowledge 3 - Question 1
Which of the following types of maintenance activities might generate Universal Waste:
Select all that apply.
a) Change-out of NiCd batteries to lithium batteries
b) Asbestos removal from hot water pipes
c) Replacement of mercury-containing instrumentation
d) Disposal of solvent soaked rags
A and C are the correct answers. NiCd batteries and mercury-containing instruments are Universal Waste. Asbestos and solvents are not.
Section III: Handling Water Discharges
Slide 45 - Handling Water Discharges
Now let’s turn to the Waste Water section of this course. First we’ll look at common problems and violations, followed by a very brief summary of the regulatory requirements. Then we’ll go into how your EMS fits in, and how pollution prevention can help.
Slide 46 - Common Problems and Violations: Wastewater
As for wastewater management, concerns for laboratories include on-site wastewater treatment, discharging liquids down drains, and stormwater runoff issues. On-site wastewater treatment facilities must meet permit limits. You must be fully informed about permit limits and other considerations before pouring any substances down the drain. Dilution is not the solution! Common problems for wastewater include:
Neutralizing a substance prior to pouring it down the drain does not necessarily mean it is safe from the perspective of the treatment works. It only means it will not eat the pipes. For example, the lead-acid from a battery can be neutralized, but the heavy metals make it unacceptable to discharge to the treatment works. The bottom line is, best practice dictates not to pour any chemicals down the drain.
Stormwater pollution has become a significant water quality concern.
Your activities such as material handling and storage are often exposed to the weather. As runoff from rain or snowmelt comes into contact with these materials, it picks up pollutants and transports them to nearby storm sewers or surface waters like rivers and lakes. The impacts include contamination of surface waters with sediment, debris, metals, and chemicals, all of which can harm fish and other wildlife as well as causing harm to public reservoirs and water systems. It also may cause the destruction of aquatic habitats or cause stream bank erosion.
Common problems related to stormwater and construction include:
Slide 47 - When do I Need a Permit?
A NPDES permit may be required for discharges from either an on-site wastewater treatment plant or from stormwater. Operators of industrial activities that have the potential to discharge stormwater to a municipal separate storm sewer system or directly to surface waters require authorization under a NPDES industrial stormwater permit.
There are individual stormwater permits for particular sectors, and general permits for others. A federal lab facility is most likely covered under a general permit. Many construction activities will be subject to a construction general permit, obtained by submitting a Notice of Intent to the state or federal authority.
More information about management of stormwater
More info about wastewater
Slide 48 - What Can I Put Down the Drain?
EPA inspectors have observed the laboratory practice of disposing of used chemicals by pouring them into sinks and drains connected to public sewage systems. This could pose serious problems for water treatment plants. Most municipalities have notification requirements or require permission to dispose of non-sanitary wastewaters into sewer systems. Decisions on what you may put down the drain must comply with municipal or county regulations concerning what can go in the drains, and Pretreatment standards the POTW has imposed upon the lab.
In general, DO NOT put substances that could pass through or create interference with treatment at the POTW, including those that:
Info if your wastewater is being sent to a POTW
Info if your wastewater is being discharged directly to the environment under a NPDES permit
Slide 49 - Using EMS to Improve your Waste Management
Introduction
Now let’s see how your EMS plays into addressing some of these common wastewater problems.
Select each item to learn about it.
Planning
Let’s look at the Planning component of the EMS pertaining to Environmental Aspects and Impacts. Start by identifying all laboratory activities and environmental aspects and impacts related to wastewater. Involve all relevant personnel that deal with wastewater and consider all routine and non-routine activities, both inside and outside of the lab setting.
Next, determine ranking criteria and identify aspects that qualify as significant. Gather baseline data for wastewater discharges, and keep the activities/aspects list up-to-date by periodically checking for new wastewater streams and changes to existing wastewater streams.
As an example of activities, aspects, and impacts related to stormwater, consider the Activity: construction or renovation. The environmental Aspect is stormwater runoff, and the Impact is water pollution. It is important to address these impacts by protecting materials from exposure to runoff.
It is important to know what your legal requirements are with respect to waste water, which may include knowing where your wastewater is going, such as to a Publicly-Owned Treatment Works or a Facility-Owned Treatment Works on site, and what preparation is needed if construction is planned. Make sure staff are aware of all legal requirements and obligations.
Some suggestions to improve compliance are to contact your treatment plant operator to determine permit limits and restrictions. Inventory materials in your labs that are restricted from discharge to POTWs. Determine if the lab discharges wastewater from a point source into a waterway and whether or not it has an NPDES permit.
If necessary, obtain the appropriate NPDES permit. Identify and make available any wastewater regulatory requirements applicable to the facility. And maintain a process to identify state or local wastewater regulations and if they have changed, and if construction is planned, contact the state about getting a stormwater permit.
Adequate identification of your wastewater activities related to significant aspects is critical to the development of your wastewater plan. In short, you need to know what to manage in order to meet your goals. From there you can consider information collected during the significance determination process for aspects associated with wastewater activities.
Establish realistic objectives and targets for wastewater management and develop environmental management programs to achieve those goals.
Identify specific actions, schedules for those actions and metrics to determine success, and be sure to gather input from all appropriate personnel (including management, operators, and contractors) to develop these objectives and targets.
Implementation & Control
Here’s how the Implementation and Control step of your EMS is applied to wastewater management. It is important to be certain that the lab has properly trained people doing the work. For operational controls, inspectors have seen instances where controls look good on paper, but when the audit trail is followed, the equipment is either not functioning properly or out of calibration. This applies to anything used to monitor the success or failure of that system, and includes storage tanks, water discharge, air emissions, and other environmental areas of the lab.
Be aware that often it is a contractor who is hired to do this work, and you will need to ensure that they comply with the lab’s operational controls. For stormwater management, operational controls address things like employee training requirements, internal audits of stormwater management procedures, or contractor and vendor responsibilities.
Checking and Corrective Action
For stormwater, conducting compliance audits will help identify nonconformity with construction stormwater permit requirements or where the Stormwater Pollution Prevention Plan and EMS controls and procedures are insufficient to address the environmental impacts of stormwater runoff.
You should periodically check for new wastewater and stormwater discharges and changes to existing discharges.
Management Review
Management review may include a background discussion of construction stormwater management efforts, a summary of measured results, and recommendations for improving performance. This review ensures the continuing suitability, adequacy and effectiveness of the EMS. It also can let managers know about the penalties that may be associated with environmental noncompliance at the lab.
Management buy-in is critical to making any changes to your EMS and implementing them, so that you can achieve your ultimate goals.
Slide 50 - Using P2 to Improve your Wastewater Management
You can reduce the amount and impact of wastewater discharges. Considering substitutions is always a good idea, and minimizing the chemicals you do use can also make a difference.
For example:
You can also use good management practices for spent chemicals and, of course, treat chemicals before disposal.
Again, remember that “neutralize” does not mean “treatment.” Treatment by a facility not permitted for treatment is a violation.
Check Your Knowledge 4 - Question 1
What types of things should NEVER be put down the drain:
Select all that apply.
a) A small amount of acid
b) A liquid that is highly tinted with USDA food coloring
c) A cooler full of ice water
d) A large amount of viscous oil washed down with hot water
e) Boiler blowdown water
A, D and E are the correct answers. In general, you should not put substances down the drain that could pass through or create interference with treatment at the POTW, including those that: are corrosive (such as acids, answer A), are solid or viscous in amounts that will obstruct flow (answer D), discharge with temperatures hot enough to interfere with biological processes used at the POTW to break down wastes (answer E)
Section IV: Managing Air Pollutants and Releases in the Lab
Slide 52 - Managing Air Pollutants and Releases in the Lab
Now let’s move on to managing air pollutants in the laboratory. Again, the general format for this section will be a presentation of common problems and violations, followed by a very brief summary of the regulatory requirements. Then we’ll go into how your EMS fits in, and how pollution prevention can help.
Slide 53 - Common Problems and Violations: Air Requirements
In this section we’ll look at the various problems and violations that have been encountered at laboratories regarding air requirements. Air emission problems at laboratories can originate from various places, including the boiler used for heating the facility or coolants used in equipment. Problems may also relate to monitoring and reporting violations or lapses.
Problems from Boilers include:
Problems from releases of coolants or ozone-depleting substances include:
Slide 54 - Common Problems and Violations: Air Requirements (continued)
Emissions may also come from friable asbestos in walls and ducts, or toxic chemicals. Friable means that it is crumbly or easily broken up. Air toxics are regulated by the Clean Air Act and may need to be permitted.
Problems related to Asbestos often pertain to renovation of asbestos-containing areas done without appropriate notification or precautions.
For Air toxics, it may be that air emissions permits are exceeded or that lab staff fail to consider emissions from lab hoods as part of the determination of whether the facility is a “Major Source” of air pollutants. There also may not be a Clean Air Act Title V permit, even though the facility is a Major Source.
More about the Clean Air Act
Info about air pollution issues
Slide 55 - How do I Know if My Boiler is Regulated?
Facilities with power generators (boilers and back-up generators) usually need permits.
Whether or not a boiler needs a permit depends on:
The permit imposes conditions on when a boiler can be used, what fuel it can burn, and what types of pollution control technologies are required. You should also check with your state and local authorities for additional requirements that may be imposed.
More information about boilers and air conditioning systems
Slide 56 - Ozone-Depleting Substances (CFCs and Halons)
The use of regulated CFCs and halons is slowly being replaced as new coolants are being used in refrigerators, air conditioners, freezers, etc. But these are not items that are typically replaced after a couple of years of use. Therefore, it is likely your lab has equipment which still contains regulated coolants. EPA regulations prohibit venting and require recycling of ozone-depleting substances during equipment servicing, repair and disposal.
Lab or service personnel who service or repair many appliances must be trained and certified through an approved program. Halons are often used as a fire suppressant in areas predominantly containing electronics.
Slide 57 - Asbestos
Asbestos can be a health hazard if it becomes airborne and is inhaled or ingested.
Labs may have asbestos-containing materials in pipe insulation, floor and ceiling tile, wall board and other building materials.
Labs must follow EPA procedures for demolition, renovation and disposal of such materials.
Qualified personnel must perform all testing and sampling on asbestos and must follow all EPA procedures.
Labs that analyze bulk building material samples for OSHA-regulated projects must participate in a nationally recognized proficiency testing program.
Lab facility maintenance personnel should not engage in any asbestos removal or abatement unless properly trained.
Asbestos is regulated under three different statutes: the Toxic Substances Control Act, the Clean Air Act, and the Occupational Safety and Health Act. TSCA regulates the abatement of asbestos from schools and other facilities and has requirements for the lab analysis of asbestos.
The CAA regulates on-site demolition, renovation and removal of asbestos-containing materials in existing structures under the National Emission Standards for Hazardous Air Pollutants regulations, or NESHAP. OSHA regulates protection against asbestos exposure with such provisions as Personal Protective Equipment, Permissible Exposure Limits, and medical exams.
More information about federal requirements for asbestos in renovation or demolition
Slide 58 - Hazardous Air Pollutants (HAPs)
There are NESHAP regulations for emissions of certain Hazardous Air Pollutants, such as mercury, beryllium, radionuclides, from certain sources and from certain equipment. A lab’s radionuclide emissions may also be subject to NESHAP if the lab does not have a Nuclear Regulatory Commission license and is not a DOE Federal facility.
If a facility is a “major source” it needs a Title V Operating Permit, which covers every federally enforceable air pollution requirement that applies to that facility. In some instances, small labs may be regulated under Title V because they are located in facilities with heating and cooling plants or other large emission points that qualify the entire facility as a major source.
While a lab may not fall under NESHAPs, they may fall under state or local air quality control regulations! Many states developed programs to address air toxins before the federal program was developed. These state programs usually have a control technology component and an ambient air concentration component.
For more information on NESHAP
Slide 59 - Using EMS to Address Your Air Concerns
Introduction
We’ll now highlight some components of your EMS that can help you address air concerns.
Select each item to learn about it.
Planning
These are some of the ways that your EMS can work to improve management of air concerns at your laboratory. Here we discuss the Planning components of the EMS, specifically Environmental Aspects and Impacts, Legal and Other Requirements, and Objectives and Targets, tailored to air-related activities.
For Environmental Aspects and Impacts, you will identify all environmental aspects and impacts of air emissions, involving all relevant personnel in the process. Ensure that the facility knows where asbestos exists in the building (for example, floor tiles, pipe wrapping, shingles, siding, etc.) and inventory existing equipment that contains regulated CFCs or halons.
Apply ranking criteria to identify aspects that qualify as significant. Keep the activities/aspects list up-to-date by periodically checking for new air emission sources and changes to existing sources
These are some suggestions to help address Legal and Other Requirements:
State and local regulations are often more stringent than federal regulations. Be sure to assess their applicability to your operations. Make certain that staff are aware of all legal requirements and obligations.
Setting objectives and targets is important to be able to determine your progress against your goals. Remember that objectives and targets are related to your policy, which includes compliance, pollution prevention, and continual improvement.
Your objectives and targets will also be influenced by factors such as your significance determinations.
Implementation & Control
These are the Implementation and Control components of your EMS that relate to air emissions management, specifically those pertaining to Training, Awareness and Competence; and Operational Controls.
You will identify personnel working with refrigerants, fire extinguishing systems and asbestos, and ensure they are properly trained. They need to be aware of emergency procedures and applicable Risk Management Plans for air emissions. Legally required training needs to be identified, conducted, and documented.
For operational controls, ensure existing operational controls are current based on your planning process, and develop procedures based on best practices. For example, notify appropriate agencies of boiler start-up and/or failure, ensure that replacement of appliances or other equipment containing regulated CFCs or halons do not contain regulated substances, remove all regulated asbestos containing material before any disruptive activity begins, handle and dispose of all regulated asbestos containing material properly, and keep facility drawings updated to accurately indicate where asbestos is located. Where necessary, develop new procedures that ensure air compliance.
Checking & Corrective Action
The Checking and Corrective Action component of your EMS offers opportunities to evaluate compliance, indentify root causes of your noncompliance, and address these causes. For example, failing to give your employees proper training may be the root cause of being out of compliance by encouraging non-compliant behavior. A possible root cause of excess emissions from boilers may be improper operations and maintenance procedures.
Any time a regulatory violation is identified from an internal or external audit or inspection, the EMS requires corrective and preventive actions be implemented and documented.
Some suggestions to help address compliance are to:
Management Review
Lastly, Management Review is critical to present and discuss results and next steps. The purpose of the review is to ensure the continuing suitability, adequacy and effectiveness of the EMS. It is also important to let managers know about the penalties that may be associated with environmental noncompliance at the lab.
The management review process is a direct reflection of the commitment of your organization to continual improvement. Management buy-in is critical to making any changes to your EMS and implementing them so that you can achieve your ultimate goals.
Slide 60 - Using P2 to Address your Air Concerns
Pollution prevention practices have the potential to reduce or eliminate air emission problems at their source. Many air pollutants of concern have safer substitutes currently in use. For example, CFCs, halons, and asbestos are not used in new equipment or construction, and alternatives are available.
When using chemicals that may be released to the air, use practices that reduce these emissions. For example, by:
Slide 62 - Challenge Case Study: GovLab
Throughout this course, we will review some incidents that occurred at a fictitious government lab facility… GovLab, and ask for your suggestions on how the lab can improve its processes to maintain environmental compliance and implement more environmentally sustainable lab practices.
GovLab is a large government research center with 4,000 civil servants and contractors. GovLab’s research uses wind tunnels and also includes the study of composite materials, structures, electronic systems and robotics.
Wastes are generated from GovLab’s research, engineering and design testing programs, as well as from the upkeep, operation, and maintenance of its equipment and facilities. GovLab uses approximately 6,000 different chemicals and materials.
Slide 63 - Challenge Case Study: GovLab (continued)
GovLab’s analytical laboratory analyzes approximately 2,000 samples annually for waste characterization purposes. The waste is characterized on a worst case basis as RCRA hazardous waste, and GovLab is a Large Quantity hazardous waste generator and has a Generator ID number.
The lab operates organic synthesis laboratories that generate glassware covered with organic residues. Oxidizing agents and solvents are used to manually remove the organic residues. The spent cleaning chemicals and rinse water are treated as hazardous waste.
Slide 64 - Challenge Case Study: GovLab (continued)
Air emissions are generated from many operations at GovLab. The test gas used in a large wind tunnel is CFC 12, an ozone-depleting compound.
GovLab’s local POTW permit requires the facility to pre-treat all rinse water. All laboratory sink drains are routed to an on-site wastewater treatment system.
GovLab implemented an EMS in 2004 in accordance with Executive Orders 13148, “Greening the Government Through Environmental Management.”
Slide 65 - Challenge Case Study: GovLab (continued)
Sue, a technician at GovLab, was getting her samples ready for analysis. When she went to get lab samples from the refrigerator, she noticed a dozen sample test tubes had spilled over. The test tubes were covered and had been placed on their sides on a tray. There was a puddle of liquid on the bottom of the refrigerator, and this had dripped onto the lab floor.
On her way to tell her supervisor, Eric, about the situation, she knocked over a beaker on her bench containing spent oxidizing agent which she had been using to clean glassware. She cleaned the spill with paper towels and threw them away in the trash, then poured the remaining liquid from the beaker into the sink. She then told Eric, who took notes on the incident along with noting how the clean up was conducted. His completed report was then filed.
Check Your Knowledge - Challenge Case Study: GovLab - Question 1
What can be said about how the samples were stored in the refrigerator?
Select all that apply.
a) There was no problem with the way the samples were stored as long as the test tubes were securely covered
b) Secondary containment is advisable but not required to contain a spill such as this
c) If the lab’s EMS was being implemented effectively, proper sample storage procedures would have been followed to avoid the spill
B and C are the correct answers. A is incorrect and C is correct because the EMS should have addressed proper storage of the test tubes in, for example, a test tube rack. B is correct because secondary containment isn’t required in this situation, but would be a good practice.
Check Your Knowledge - Challenge Case Study: GovLab - Question 2
Which element(s) of the EMS do you think GovLab should focus on to begin addressing the problems with the spills?
Select all that apply then select the Submit button.
a) Planning
b) Implementation and control
c) Checking and Corrective Action
d) Management Review
A, B, C and D are the correct answers. A, because the samples and glassware cleaning should have been evaluated as a significant environmental aspect. Sue and other staff should have been aware of regulatory requirements about proper storage of hazardous waste. B, because Sue should have been trained in proper clean up procedures and the spill events should have been communicated broadly to others at the lab as a lesson learned. C, because if a periodic audit had been done, the storage problems would have been identified, and D, because Eric filed his notes and did not communicate with lab management about the events.
Check Your Knowledge - Challenge Case Study: GovLab - Question 3
What is a possible compliance issue concerning the spill from Sue’s bench?
Select all that apply.
a) The location of the container
b) The type of container
c) The identity of the waste
d) How the spill was cleaned up
B, C and D are the correct answers. A is not correct because Sue’s bench could have been a Satellite Accumulation Area. B is correct because the container should have been covered if it was storing hazardous waste, C is correct because this material was considered a hazardous waste, D is correct because it should have been cleaned up using absorbents and disposed of as hazardous waste.
Check Your Knowledge - Challenge Case Study: GovLab - Question 4
When Sue poured the remaining spent oxidizing solution down the drain, she was violating the lab’s pretreatment permit with the local POTW.
a) True
b) False
The answer is False. The sink drain was routed to an on-site treatment plant, and not directly to the POTW, so the waste was pretreated.
Check Your Knowledge - Challenge Case Study: GovLab - Question 5
Did these two employees complete all the actions you would recommend? What else would you suggest?
Select all that apply.
a) Send documentation to the state regulatory agency
b) Ensure Sue gets proper training on spill clean up
c) Remind Sue about being careful with containers
d) Share the information about the spills with all parts of the laboratory including peer safety officers and with management
B and D are the correct answers. In this case, there is no Federal requirement to send documentation to a state agency. Training should be part of the lab’s EMS, as well as its Hazardous Waste Contingency Plan in the case of a LQG, and should be more effectively implemented. Reminding Sue about being careful with containers is not an effective way to ensure it doesn’t happen again. Sharing information with peers and with management should be a part of the lab’s EMS.
Check Your Knowledge - Challenge Case Study: GovLab - Question 6
Is it a regulatory violation for GovLab to be using CFC 12 in their wind tunnel?
a) Yes
b) No
No is the correct answer. They may use CFC 12 in their wind tunnel, but they must not allow venting and must recycle the ozone-depleting substance during equipment servicing, repair and disposal. Lab or service personnel who service or repair the equipment must be trained and certified through an approved program.
Slide 67 - Chemical Management
Now let’s turn to other environmental concerns, specifically toxic chemical management, reporting and communication. This section starts with a presentation of common problems and violations, followed by a very brief summary of the regulatory requirements. Then we’ll look at how your EMS fits in, and how pollution prevention can help.
Slide 68 - Common Problems and Violations: Chemical Management
Communication of chemical hazards is covered by several different statutes. The different requirements pertain to different chemicals with specific thresholds for different circumstances and with different reporting requirements. Together, they address the use of chemicals on site and releases of these chemicals. It is important to be familiar with each one.
Common problems and violations relating to chemical management include failure to:
The NRC receives all reports of releases involving hazardous substances and oil that trigger the federal notification requirements under several laws.
Slide 69 - Chemical Management: Notification and Reporting
These requirements are intended to help increase public knowledge and access to information on the presence of hazardous chemicals and releases of these chemicals in communities. According to the Emergency Planning and Community Right-to-Know Act, or EPCRA, when you have certain chemicals on site above a threshold amount, you must annually submit a list of these chemicals to the State Emergency Response Commission, the Local Emergency Planning Committee and the local fire department. Facilities either submit a Tier I or a Tier II form.
Federal facilities that meet certain thresholds are also required to report annually to EPA any routine toxic chemical releases or transfers from their facilities under the Toxic Release Inventory (TRI). TRI is an EPA database that contains information on toxic chemical releases and waste management activities reported annually by certain industries and by federal facilities. As part of the Community Right-to-Know provisions of EPCRA, the public has the right to access any of this information.
More info about EPCRA chemical management at federal laboratories
More info about Tier I and Tier II Inventory Forms
Slide 70 - Chemical Management: Accidental Releases
When there is a release of a reportable quantity of any extremely hazardous substance or CERCLA hazardous substance, the facility must notify the State Emergency Response Commission (SERC), the Local Emergency Planning Committee (LEPC) and the National Response Center.
States may have additional reporting requirements. Know what substances you have and what quantities released are reportable before an incident happens.
This is separate from the reporting requirements for discharges of oil, and the term "hazardous substance" does not include petroleum or natural gas. Incidents involving petroleum and non-petroleum oils are addressed under Clean Water Act authorities and are covered later in this course.
Learn more about Reportable Quantities
Learn more about the National Response Center
Slide 71 - Using EMS for your Chemical Management
Introduction
Now let’s look at ways your EMS can provide a framework for improving chemical management and notification practices at your laboratory.
Select an item to learn about it.
Planning
These are the three sets of Planning components of the EMS tailored to chemical management activities, starting with the identification of environmental aspects and impacts of chemical releases, both routine and non-routine.
Identify all related requirements, and establish your objectives, targets and EMPs. For example, if your objective is to maintain compliance with EPCRA, your target may be to have no audit findings or violations.
Implementation & Control
For Implementation and Control, there are specific training and operational controls activities you should be aware of to ensure that your EMS adequately addresses the proper response to chemical release emergencies as well as routine reporting requirements for chemicals used or produced on site.
These include:
Checking & Corrective Action
For checking and corrective action, your EMS gives you a framework to monitor the lab’s significant aspects with respect to hazardous and toxic chemicals, to assign responsibilities for monitoring responsibilities, data collection, compliance audits, and reporting. Any time a regulatory violation is identified from an internal or external audit or inspection, the EMS requires corrective and preventive actions be implemented and documented.
To evaluate compliance:
Management Review
Giving management an opportunity to review your findings and activities will allow adequate resources to be allocated and needed changes to be enacted. Keep management updated on EMS responsibilities and the resources needed to achieve chemical management and communication objectives and targets. Make and solicit recommendations for improving performance to achieve your objectives and targets, and ensure that management acts on and supports planned changes or new programs that could affect chemical management.
Check Your Knowledge 5 - Question 1
EPCRA requires the reporting of hazardous chemicals present at your facility to which of the following:
Select the answer.
a) The State Emergency Response Commission (SERC)
b) The Local Emergency Planning Committee (LEPC)
c) The fire department
d) All of the above
D is the correct answer. Federal facilities must submit notifications of hazardous materials or extremely hazardous materials stored on site and their activities to the LEPC, SERC and fire department according to the Emergency Planning & Community Right to Know Act, or EPCRA.
Slide 73 - Managing Underground Storage Tanks, Oil Storage, and Underground Injection of Waste
In this section we’ll look at three other regulatory areas: underground storage tanks, oil storage tanks, and underground injection of waste.
Slide 74 - Common Problems and Violations: Underground Storage Tanks
Problems for underground tanks often relate to improper installation, failure to conduct proper leak detection and notification practices, and performing maintenance.
One way to avoid some of these problems, particularly that of performing required maintenance and calibration, may be to include operation programming and maintenance in equipment installation contracts. But even if your contractor is required to perform these activities, your facility will still be liable if the contractor fails to do so.
Slide 75 - Underground Storage Tanks
Regulations require owners and operators of new and existing underground tanks to prevent, detect, and clean up releases. They also ban the installation of unprotected steel tanks and piping. The federal UST regulations apply only to underground tank systems that store petroleum or certain hazardous substances. The UST program is primarily implemented by the states, rather than the federal government. Check with your state or local regulatory authority about particular registration, reporting and recordkeeping requirements in your area.
Note that emergency generator USTs are partially regulated. “Dual-Use” tanks that store heating oil and service emergency generators are regulated. Check federal, state and local regulations.
Information about underground storage tanks
Slide 76 - Using EMS to Manage Your Underground Storage Tanks
Introduction
Now we’ll look at how the EMS can help you improve underground storage tank management in the laboratory.
Select each item to review.
Planning
These are the Planning components of the EMS:
For Environmental Aspects and Impacts:
For Legal and Other Requirements:
For Objectives, Targets and Environmental Management Programs:
For example, an UST-related Activity may be UST deliveries, the Aspect would be hazardous/toxic material releases, and the Impact would be land and water contamination. An example of Environmental Management Programs for groundwater contamination may have the objective of eliminating the potential for contamination from USTs with the target of training all appropriate personnel on monitoring system and reducing the number of spills to zero.
Implementation & Control
Activities under Implementation and Control address Training and Operational Controls. It is important to communicate lessons learned throughout the facility, as this is an important component of the EMS. Some laboratories have a high turnover of staff whose responsibility it is to manage or maintain tanks. Ensure that each new employee is trained and aware of his or her responsibilities under the UST requirements and EMS.
Operational controls can help with USTs in ensuring that all monitoring equipment is operating correctly and that all periodic monitoring is performed and documented in accordance with regulatory requirements.
Checking & Corrective Action
Noncomformities for USTs that may be identified include water levels in the tanks not being monitored monthly, facilities using inventory control not reconciling inventory volumes daily, or automated tank gauging systems not being able to detect a slow leak. Consider expanding existing UST monitoring and measurement reporting; for example, monthly release detection monitoring, if additional monitoring would help the facility meet its targets.
Management Review
If management is not aware of the results of your EMS activities, it is unlikely that improvements can be made. Communicate your activities along with recommendations to management. Let them know of the penalties that may be associated with environmental noncompliance at the lab.
Slide 77 - Common Problems and Violations: Oil Stoarge
We just touched upon underground tanks, and earlier in the course we covered releases of hazardous chemicals. This section addresses release prevention for oil in tanks. Keep in mind that oil is defined quite broadly by the Spill Prevention Control and Countermeasure regulations. Most problems and violations pertaining to oil storage relate to the facility’s SPCC plan under the Clean Water Act.
Although one of the violations noted is not having the Plan signed by a Professional Engineer, not all Plans have to be signed by a certified PE. A “qualified” facility can certify their plan themselves without a certified PE. A “qualified” facility is a facility that has an aggregate aboveground storage capacity of 10,000 gallons or less, has had no single discharge exceeding 1,000 gallons, or no two discharges where each exceeded 42 gallons within any 12 month period in the 3 years prior to the SPCC Plan self-certification date, or has been in operation for less than 3 years.
Slide 78 - Oil Storage
Not all facilities are subject to SPCC regulations. They must meet three criteria:
The regulations apply to all containers 55 gallons or larger.
More information about SPCC
Information about oil storage tanks
Slide 79 - Using EMS to Manage your Oil Storage
Introduction
Your EMS also provides a framework to help you manage your on-site oil storage.
Select each item to review.
Planning
Identify all environmental aspects and impacts of oil storage. These include:
Determine what legal requirements are applicable, based on total on-site storage capacity. These include:
Implementation & Control
These are some of the Implementation and Control activities to consider: Identify and provide training required for regulatory compliance as well as additional training to ensure process control and adherence to EMS procedures. Be sure to conduct and document all required training.
Checking & Corrective Action
To evaluate compliance
Note that states often regulate oil storage differently than the federal government.
Whenever a regulatory violation is identified from an internal or external audit or inspection, the EMS requires corrective and preventive actions be implemented and documented.
Management Review
Include Management Review in implementing your EMS to address oil storage. Be sure to let them know of the penalties that may be associated with environmental noncompliance at the lab. Management Review is critical to present and discuss results and next steps. The purpose of the review is to ensure the continuing suitability, adequacy and effectiveness of the EMS. The management review process reflects the commitment of your organization to continual improvement.
Slide 80 - Common Problems and Violations: Underground Injection
Problems associated with underground injection of wastes may be the lack of a permit or the failure to comply with notification or recordkeeping requirements, such as the failure to:
Slide 81 - Underground Injection
Underground Injection Control (UIC) regulations are designed to protect underground drinking water from contamination. Injection wells have a range of uses that include waste disposal, enhancing oil production, mining, and preventing salt water intrusion. As with many environmental regulations, the state agency is the primary enforcement authority for the UIC program.
The underground injection of wastes other than the use of septic systems for sanitary waste is generally prohibited, and if allowed, the well is strictly regulated. Injection must be authorized under either general rules or specific permits. Lab managers in facilities that discharge wastewater to a septic system should caution personnel that any pollutant discharged down the drain has the potential to contaminate the environment. Check to make sure you know how all your lab drains or other pipe discharges are routed.
There are five classes, or types, of injection wells based on similarity in the fluids injected, activities, construction, injection depth, design, and operating techniques. This categorization helps ensure that wells with common design and operating techniques are required to meet appropriate performance criteria for protecting drinking water. A laboratory must know what type of well they have, so that they know what they need to do to be in compliance.
Learn more about SDWA
Learn more about UIC
Slide 82 - Using EMS to Manage Your Underground Injection (UIC) Program
Introduction
Now let’s see how you can use EMS to address underground injection.
Select each item to review.
Planning
Having a well-run EMS will help ensure that any UIC wells your facility may have are operating in an environmentally protective and compliant way.
For Planning, you will want to identify environmental aspects and impacts of your UIC wells. Determine what class your wells are in and what requirements you need to comply with.
Implementation & Control
For Implementation and Control, you will want to ensure that training is provided pertaining to the UIC program and your EMS.
Checking & Corrective Action
For Checking and Corrective Action, you will want to conduct periodic compliance audits and determine if there are any noncomformities.
Management Review
You will want to present the results of your monitoring efforts to management and obtain their buy-in for any needed changes.
Slide 83 - Using P2 to Address Storage Tanks, Oil Storage and Underground Injections
Pollution prevention (P2) in all three of these areas is mostly oriented toward reducing the quantity of chemicals or oil used and stored on site. Prevention of accidental releases is also key. One idea for reducing the amount of oil stored on site would be to eliminate an onsite fuel pump and switch to doing all fueling at a local gas station, allowing your facility to get rid of the tank.
Check Your Knowledge 6 - Question 1
A laboratory has two 10,000 gallon underground storage tanks. Identify some of the problems to avoid.
Select all that apply.
a) Tanks and piping not installed according to manufacturers’ specifications
b) Failure to provide corrosion protection devices for tanks and piping
c) Lack of or inadequate release detection systems for tanks and/or piping
d) Dose limits and monitoring
A, B and C are the correct answers. A, B and C are all requirements for underground storage tanks under the SPCC regulations. Answer D, dose limits, does not relate to the SPCC regulations.
Challenge Case Study: Tank Trials
Slide 86 - Challenge Case Study: Tank Trials
Sal is new to GovLab and just assumed responsibility for the environmental management of the facility. To learn about the facility, he meets with the lab director and has a tour. He learns the building has three 5,000 gallon aboveground storage tanks, two containing No. 2 heating oil and one containing kerosene for steam generation and heating the building. He is told that the lab has never had a discharge. Upon inspection, Sal noticed one of the tanks was much newer than the others. He went back to the files to examine the facility’s SPCC Plan. Upon review of the SPCC Plan he noticed only two tanks were listed.
Slide 87 - Challenge Case Study: Tank Trials (continued)
Further, the lab director tells Sal that there are two underground storage tanks (USTs) including: a 5,000 gallon gasoline tank for fueling GovLab vehicles, and a 1,000 gallon diesel fuel tank used solely for an on-site emergency power generator in the event of a power outage. After reviewing GovLab’s UST records and files, Sal learns that both tanks are constructed of steel, but is relieved to learn that these tanks were provided with corrosion protection (cathodic protection), shortly after they were installed ten years ago. His relief is short-lived however, when he learns that the diesel fuel UST that services the emergency generator was not provided with leak detection for the tank or piping.
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What are some things Sal would look for with respect to the SPCC regulation?
Select all that apply.
a) A list of all the tanks at GovLab is included in the SPCC Plan
b) Ensure the SPCC Plan was filed with the regulatory agency
c) A list of all the 55 gallon drums is included in the SPCC Plan
d) Check that the SPCC had been reviewed in the past 5 years
A, C and D are the correct answers. A list of all tanks must be included in the SPCC Plan if the facility has an aggregate aboveground storage capacity greater than 1,320 gallons or a completely buried storage capacity greater than 42,000 gallons. 55-gallon drums are included, and the Plan must be reviewed every 5 years. However, the SPCC Plan does NOT need to be filed with the regulatory agency.
Check Your Knowledge - Challenge Case Study: Tank Trials - Question 2
Since GovLab is a federal laboratory, its oil tanks are covered by:
Select all that apply.
a) Only Federal regulations
b) Federal and State regulations
c) State regulations only
B is the correct answer. As a Federal Lab, both Federal and State regulations apply.
Check Your Knowledge - Challenge Case Study: Tank Trials - Question 3
What kind of leak detection does the 1,000 gallon diesel UST servicing the emergency generator require under federal regulations?
Select your answer.
a) Tank and Piping must be provided with leak detection.
b) Only the Tank must be provided with leak detection.
c) Only the piping needs leak detection.
d) Neither the piping nor the tank require leak detection under federal regulations.
D is the correct answer. Subpart D of the Federal Regulations for leak detection does not apply to UST systems that store fuel solely for emergency power generators. But Sal should still check with the state regulations to ensure that the state does not have more stringent requirements.
Check Your Knowledge - Challenge Case Study: Tank Trials - Question 4
What are some immediate things that Sal needs to be concerned about regarding the 5,000 gallon gasoline tank at the fuel station?
Select the answer.
a) If monthly monitoring records for leak detection of the tank are maintained on site.
b) The piping is not provided with an automatic line leak detection.
c) If the piping has ever been tested for leaks.
d) a and b
e) a, b and c
E is the correct answer. Although Sal should be concerned if the piping is leaking, since it has no leak detection system, he also needs to be concerned about violating federal leak detection requirements for USTs. Sal can’t forget that the functionality of that line leak detection system must be checked annually to ensure that it is working correctly. He must also ensure that monthly monitoring records of the line leak detection system and the tank are kept on file for the past year. Finally, Sal needs to check the state regulations that may be more stringent for leak detection.
Slide 89 - Other Environmental Requirements
There are a few other environmental requirements we want to cover before you complete the course. Some are enforced by EPA, others by other federal agencies.
Slide 90 - Other Laws Enforced by EPA
These are a few additional environmental statutes that are important for you to be aware of from a compliance standpoint.
The Federal Insecticide, Fungicide, and Rodenticide Act provides for federal regulation of pesticide distribution, sale, and use. All pesticides distributed or sold in the United States must be registered (licensed) by EPA. Before EPA may register a pesticide under FIFRA, the applicant must show, among other things, that using the pesticide according to specifications "will not generally cause unreasonable adverse effects on the environment."
The Comprehensive Environmental Response, Compensation, and Liability Act -- otherwise known as CERCLA - provides a Federal "Superfund" to clean up uncontrolled or abandoned hazardous-waste sites as well as accidents, spills, and other unplanned releases of pollutants and contaminants into the environment. Through CERCLA, EPA was given power to seek out those parties responsible for any release and assure their cooperation in the cleanup. We talked about CERCLA earlier in the course, but not about the Superfund provisions of the Act.
The Toxic Substances Control Act - otherwise known as TSCA - was enacted by Congress to give EPA the ability to track the 75,000 industrial chemicals currently produced or imported into the United States. EPA repeatedly screens these chemicals and can require reporting or testing of those that may pose an environmental or human-health hazard. EPA can ban the manufacture and import of those chemicals that pose an unreasonable risk. Also, EPA has mechanisms in place to track the thousands of new chemicals that industry develops each year with either unknown or dangerous characteristics.
The Safe Drinking Water Act (SDWA) was established to protect the quality of drinking water in the U.S. We touched on this under the UIC program. This law focuses on all waters actually or potentially designated for drinking use, whether from above ground or underground sources, and
The National Environmental Policy Act (NEPA) ensures that all branches of government give proper consideration to the environment, prior to undertaking any major federal action that significantly affects the environment. Environmental Assessments (EAs) and Environmental Impact Statements (EISs), which are assessments of the likelihood of impacts from alternative courses of action, are required from all Federal agencies and are the most visible NEPA requirements.
Slide 91 - Health and Safety
OSHA is a federal agency that administers regulations that will also affect you at a laboratory. It is important to be aware of OSHA requirements.
OSHA sets enforceable permissible exposure limits to protect workers against the health effects of exposure to hazardous substances. PELs are regulatory limits on the amount or concentration of a substance in the air. They may also contain a skin designation. OSHA PELs are based on an 8-hour time weighted average (TWA) exposure.
OSHA requires the use of personal protective equipment to reduce employee exposure to hazards when engineering and administrative controls are not feasible or effective in reducing these exposure to acceptable levels. Employers are required to determine if PPE should be used to protect their workers. If PPE is to be used, a PPE program should be implemented. This program should address the hazards present; the selection, maintenance, and use of PPE; the training of employees; and monitoring of the program to ensure its ongoing effectiveness.
OSHA regulations for hazardous chemicals address storage and handling of flammable liquids; storage of compressed gases, and communicating chemical hazards to employees under the Laboratory Standard and the Hazard Communication Standard.
Wastes from labs that work with bloodborne pathogens, microorganisms, recombinant DNA (rDNA) technologies, lab animals, or human body fluids must be specially managed so as to reduce the potential for personnel exposure and environmental release.
Occupational Exposure to Hazardous Chemicals in Laboratories
29 CFR 1910.1450
Bloodborne Pathogens Standard
29 CFR 1910.1030
Learn more about OSHA requirements at laboratories
Slide 92 - Nuclear and Radioactive Materials
Similarly, the NRC administers regulations that may affect your lab.
The Nuclear Regulatory Commission's mandate to protect public health and safety and the environment, and to provide for the common defense and security, includes regulation of byproduct material used for commercial, medical, and academic purposes. The Energy Policy Act adopted August 8, 2005, amended the definition of byproduct material to include additional types of radioactive materials.
The NRC also regulates:
More information on the Nuclear Regulatory Commission
Slide 94 - Summary Recap
In closing, you should now be able to understand common environmental compliance problems found in laboratories, and generally what the federal law requires. You should also have learned about how EMS and P2 may help your facility attain or maintain compliance. We hope you have enjoyed the course, and the challenging questions asked along the way, and are now ready to tackle some of these problems at your laboratory!
Slide 95 - End of Course