Professor Diba Khan-Bureau
Date of Speaker: Wednesday May 14, 2014
Resource Conservation and Recovery Act
David stokes was very informative and enlightened me about the Resource Conservation and Recovery Act, something I’ve never heard of before. David Stokes is an Environmental Analyst and is a part of the Waste Engineering and Enforcement division, working at Electric Boat in Groton Connecticut. He has a good friendship with professor Diba, as well as a long work history with her from Electric Boat. It is really great to see that David Stokes has offered to speak at Three Rivers year after year. This seminar was based off of a very interesting topic, making it a great ending for our 2014 Environmental Science Seminar class.
RCRA stands for the Resource Conservation and Recovery Act, which is an act that was passed by Congress in 1976, to protect the health of humans and the environment from the potential hazards of waste disposal. It has been enacted to conserve energy and natural resources, as well as reduce the amount of waste generated, and to ensure that wastes are managed in an environmentally sound way. It’s a preventative law basically, called the “Cradle to Grave”, which is designed to prevent future superfund sites, or abandoned sites. The RCRA is a self implementing regulation, unlike the Clean Water Act, which is restricted to using permits to control pipe discharges. However, the regulatory requirements are determined by “degree of risk”. Degree of risk include the amount of waste generated by a place monthly, the amount of waste on-site at any one time, the toxicity of generated or stored waste, and how waste is handled. The riskier the method may be, the more regulatory requirements there are. David stokes gave us a very detailed background on just about everything that the RCRA includes. There are two sets of requirements; requirements for those that generate hazardous waste, and requirements for waste management's activities that require a permit. Those that generate hazardous waste are known as “generators”, which are commonly known to keep hazardous waste for short time frames, using less risky management methods. There are small quantity generators, and there are large quantity generators. Small quantity generators generate between a 100 to 1000 kilograms per month, and there is a 180 day storage limit. Small quantity generators have less substantial management requirements compared to large quantity generators. Large quantity generators generate greater than 1000 kilograms per month and there is only a storage time of 90 days. If businesses fail to cohere with the storage days and do not meet substantial requirements, the result is a hefty fine, or either the requirement to get a permit. Businesses need to obtain multiple permits if they are treatment, storage, or disposal facilities. This also includes if they are a commercial facility, which takes in other businesses waste. Permits are also required if these facilities plan on storing hazardous waste long term, and are facilities that use their land as disposal for hazardous waste. One thing that I learned from this seminar was that businesses documenting their intake of hazardous waste or storage is not easy, nor is all the paperwork that is associated with it. Permits are required, inspections, employee trainings, emergency response plans, shipping records, etc. Failure to follow specific instructions is not a joke, and is taken seriously; penalties include civil and criminal, civil violations, being the most common, can be up to $25,000 a day, and criminal violations can be up to $50,000 a day, and also jail time is a possibility. The difference between civil and criminal penalties is that one is a violation of regulations and the other is when it is obvious that they are violating. David Stokes talked a lot about permits, which was interesting, but I thought the most interesting part was learning about what actually are hazardous waste and how they become labeled “hazardous”.
There are three steps in determining whether a certain substance is hazardous or not. The first step is to determine if the waste is a solid waste. “Solid waste means any garbage or refuse; sludge from a waste water treatment plant, water supply treatment plant, or air pollution control facility; and other discarded material, including solid, liquid, semisolid, or contained gaseous material resulting from industrial, commercial, mining, and agricultural operations, and from community activities. Solid wastes include both hazardous and nonhazardous waste”(EPA). The second step would be determined if it is a hazardous waste. A waste can be considered hazardous if it is ignitable, corrosive, reactive, or exhibits a characteristic of hazardous. The third step would be to determine if the waste is excluded. A hazardous waste exclusion example would be drilling fluids from oil and gas exchange. As complicated as all this may seem, it actually is really helpful information. I was very surprised that household items such as lead-acid batteries, used electronics, fluorescent light bulbs containing mercury, fire alarms, are all considered hazardous waste!
David Stokes did a great job presenting to the class. Learning about Hazardous waste was completely new for me, but it was a very interesting topic, and he kept my interest throughout the class. It is important to have laws regarding hazardous waste storage, production, and disposal, because handling hazardous toxic chemicals improperly can be detrimental to human health and negatively affect the environment. I’d like to conclude this essay on a more personal note by saying that taking this class has been an absolute pleasure. I’ve learned so much about the environment and how to become a more sustainable person and a good steward. Because of this class I have become a more educated and environmentally aware, thanks to Professor Diba and the speakers who take the time out of their busy lives to come speak to our Environmental Seminar class at Three Rivers. Taking this class has been an absolute pleasure. Thank you Professor Diba for enlightening me on how to be a sustainable person.