**The Manager's Tool Kit**

**for Environmental Compliance & Pollution Prevention**

**Module 3 of 6**

**A Telecast Originating from the BLM National Training Center in
Phoenix, Arizona**

**February 21, 2002**

This transcript is from the closed-captioning file produced during the
telecast.

It may contain errors and omissions in transcription.

Announcer: the Bureau of Land Management Satellite Network and The USDA
Forest Service Present Live from the BLM National Training Center in
Phoenix, Arizona the Manager\'s Tool Kit For Environmental Compliance
and Pollution Prevention. And Now, the Host of Your Program, Tony
Garrett.

T. Garrett: Hello and Welcome To Module 3 of Our Six‑part Interagency
Course on Environmental Compliance and Pollution Prevention. In Today\'s
Telecast We\'ll Examine the Emergency Planning And Community Right to
Know Act, EPCRA, and Special Pollution Management. Here Are Our
Objectives for Today. Upon Completing this Module You\'ll Be Able to
First State What Your Responsibilities Are To Comply with the Six
Notification and Reporting Requirements under EPCRA. And Second, You\'ll
Know What Rules Apply to Special Pollution Management, as Well as the
Considerations for Making Decisions. Here\'s Today\'s Schedule. In Our
First Segment We Will Be Covering the Six Requirements of EPCRA and
We\'ll Have a Few Exercises for You. That Will Run about an Hour. Then
We\'ll Take a 15‑minute Break. When We Return, We\'ll Turn to The Issue
of Special Pollution Management. That Includes Used Oil, Lead, Asbestos,
Radon, Mercury and Unexploded Ordinance, Including Explosives Found as
Abandoned Mine Sites. And near the End of Our Broadcast We\'ll Have the
Third Installment of Our Game Show \"The Hazmat Challenge.\" Once Again
Those East of the Continent Divide Will Be Squaring off Against the West
as We\'ll Be Testing Your Knowledge About the Material We\'re Covering.
In Today\'s Game Every Participant Will Be Awarded this Fabulous Prize!
The Official \"Hazmat Challenge\" T‑shirt. So Stay Tuned for \"The
Hazmat Challenge.\" Again, Today Our Team of Instructors Is Lead by ‑‑
Led My Martin Thrasher. Welcome Back Martin.

M. Thrasher: Good Morning, Tony.

T. Garrett: Also Back with Us This Week Is Frank Mills, the National
Coordinator for Environmental Enforcement at the USDA Forest Service.
Hello, Frank.

F. Mills: Hello, Tony, It\'s Good to Be Here Today.

T. Garrett: and Completing Our Instructional Team from BLM\'s Washington
Office Is Ken Morin, the National Lead for the Bureau\'s Cashe Audit
Program. Thanks for Coming Back.

K. Morin: Thanks, Tony. I Would like to Start off Today Answering a
Question I Had Last Week and it Was Related to Computers and How Do You
Properly Dispose of Debris or Old Printers, Old Monitors and Old Cpus
Themselves. I Know Most of You Are Probably Donating Them. You\'re Going
to Have Some Equipment Nobody Wants, It\'s a 386, It\'s So Old or it
Just Doesn\'t Work. There\'s Enough Lead, Cadmium and Chrome in this
Equipment That it Is Technically a Hazardous Waste. So to Dispose of it
Properly, I Did Some Research and There\'s Several Companies out There
That Will Actually Take Back Equipment So it Can Be Either Recycled,
Precious Metals Reclaimed, the Plastic Reclaimed, the Lead Reclaimed, Et
Cetera. The First Three, Hewlett‑packard, Ibm, Dell. The First Two Will
Accept Anyone\'s Computers and You Can See They\'re Charging a Fee
Anywhere from 13 to \$34 to Accept It. The Last Bullet down There, Dmc
Electronics Recycling, Is Just One of the Larger Firms in the Country
That Will Accept Computers. Now, this next Slide Has Two Bullets on It,
and the First One Is Actually a List of Companies Throughout the Country
That Will Accept Computers for Recycling. If You Go to the Website for
the Electronic Equipment Recycling Contact List, You\'re Going to See
Every State in the Country Listed, but If You Click on Alaska You Will
See There Is Actually Nobody There. They\'re Trying to Facilitate
Getting More and More Companies To Participate in this Service. Alaska,
Arkansas, West Virginia, Several Other States, There\'s Nobody Listed at
All. But for California There must Be At Least 30 Companies Listed. So
That First Website Is Probably the Most Useful for You. If That Answers
Your Question, Great, If it Doesn\'t, Send Me Another E‑mail and I\'ll
Get You Some More Information.

T. Garrett: Thank You, Ken. In Addition to the BLM and Forest Service
Employees Who Are With Us Today We Welcome Employees from the U.s. Fish

&

wildlife Service, the National Park Service, the Bureau of Land
Management And, Of Course, Any Others Who May Be Watching. We Want You
to Know Your Participation Is Very Important To the Success of These
Satellite Training Sessions. And, Again, to Help You Communicate in Real
Time with Our Instructors We\'re Going to Use Push‑to‑talk Technology So
You Can Interact with Us Directly. We Encourage You to Use Those
Push‑to‑talk Microphones When You Have a Question or Something To Share
with Our Instructors And Our Viewers. Whenever You Do Push to Talk With
Us, We Ask That You Begin By Stating Your Name and Location. We\'ll
Acknowledge Your Call and Then You Can Proceed with Your Question or
Comment. That Helps Us Avoid Confusion When More than One Person Is
Calling In. And to Help Manage All This, We\'ll Let You Know When It\'s
Ok To Push to Talk by Putting a Green Light in the Upper Right Corner of
Your Screen. A Green Light like That One. During Periods When We\'d
Prefer That You Concentrate on the Material Being Presented and Hold
Your Questions for the Moment, We\'ll Put up a Red Light In the Corner
like This. We\'ll Try to Keep the Green Light on as Much as Possible
Because We Do Want to Get Feedback from You and Answer All Your
Questions. Now, If for Some Reason You Did Not Get the Phone Number and
the Pass Code for the Push‑to‑talk Telephone Bridge for Your Agency,.
Please Call Our Operator at 602‑943‑2279 to Get That Information. If You
Don\'t Have a Push‑to‑talk System at Your Viewing Site, We Still Want to
Hear from You, and We Invite Your Questions and Comments. We Encourage
You to Participate By Telephone or Fax. You Can Call Us Toll‑free at
These Numbers\.... We\'d Also like to Mention Beginning with Module 4
March 7th We Will Be Going on the Air 10 Minutes Earlier to Give You a
Chance to Check in Earlier and Test Your Push‑to‑talk Connectivity, Give
Us Feedback On the Course. We Will Set Aside 20 Minutes and Offer That
Informal Dialogue and Then We\'ll Start Our Show at 10 Minutes past the
Hour. So During That 20‑minute Period, You Can Visit, Tell Bus Your
Expectations for the Module and Test out Your Interactive Equipment.
Look for That Change Starting With Our next Module Starting Two Weeks
from Today, an Informal Open Mic Session Running from 10 Minutes Before
The Hour until 10 Minutes after The Hour. Now, Those of You Who Have
Been With Us During the Last Two Weeks Will Remember We Have Been
Checking in with One of Our Participants, Mark Hemingway at Yellowstone
National Park Because We Were So Impressed With His Commute to the
Training. His Commute Is 140 Miles Round Trip by Snowmobile. Last Week
He Braved the Frigid Temperatures, Snow and Darkness And Buffaloes to
Get to the Downlink Site. Mark, If You\'re with Us Again Today, We
Invite You to Check in With Us on Your Push‑to‑talk Microphone and Tell
Bus Your Trip this Morning. Mark?

Caller: Yes, I\'m Here. And the Trip this Morning Was Real Cold.

T. Garrett: No Buffaloes this Morning?

Caller: Not on the Road.

T. Garrett: All Right. It\'s Great to Have You Back. And Neither Rain
Nor Sleet Nor Snow Nor Gloom of Night Nor Buffaloes Will Stay the
Resource Manager from His or Her Haz‑mat Training Bullpen You Travel
Cross‑country to Get to Your Downlink Site or Just down the Hall, We
Thank You for Being With Us. We Know It\'s Not Easy to Find The Training
You Need. We Appreciate You Doing That. By Now You Should Have Reg
Stuffed for this Satellite Class And Received the Course Training
Materials, the Manager\'s Tool Kit. If Not, See Your Agency\'s Website
to Download the Tool Kit. These Contain an Outline of the Training
Content. The Course Goals and Objectives And Other Useful Resources. And
Now Let\'s Get down to the Coursework in EPCRA. Here Once Again Is
Martin Thrasher.

M. Thrasher: Thanks, Tony. Welcome Module 3. I Wanted to Emphasize
Something That Tony Mentioned a Few Minutes Ago about Using Your
Push‑to‑talk or Telephoning in Or Using the Fax to Ask Questions. Ken
and Frank and I Are All Used To Traditional Classroom Training and We
Much Prefer an Interaction with the Students. So at Any Time, We Can\'t
See You Raise Your Hand, but at Any Time You Can Use Push to Talk or
Call Or Fax In, We Would Be Glad to Interrupt What We\'re Talking About
and Address Your Particular Question. That\'s What We\'re Here For. Now,
in this Module We Are Going To Be Covering EPCRA, or the Emergency
Planning and Community Right to Know Act. Then We\'re Going to Be
Covering Some Other Special Ways and ‑‑ Special Wastes and Special
Materials That Are Particularly Important to Resource Management
Agencies. But Before I Do That, I Wanted To Go Back to this Schematic, a
Rather Simple Schematic, of the Hazardous Materials System So We Have
That Well in Mind as We Discuss the Emergency Planning Community Right
to Know Act and Some of the Special Wastes Today. As I Had Described to
You in the First Module, We Used this Term Hazardous Materials as Kind
of a Generic Term to Refer to the Universe of Regulated Materials. So
Anything That Has Regulated ‑‑ Regulations Associated with It, We Refer
to It as Hazardous Materials. But as Managers, We\'ve Got to Go Far
Beyond Determining Whether Or Not Something Is a Haz‑mat or Hazardous
Material. Now, Within the Scope of Hazardous Materials We Have a Set of
Commodities That We Call Hazardous Substances, and Those Are Regulated
under the Comprehensive Environmental Response Compensation and
Liability Act, or CERCLA. We Covered That During Module 1. Then in
Module 2 We Covered Another Set of Commodities That We Call Hazardous
Wastes, and Those Are Regulated under What\'s Called the Resource
Conservation And Recovery Act. Now, Beyond That, and One of the Things
We\'re Going to Be Covering Today in Detail, Are a Set of Commodities
That We Call Extremely Hazardous Substances, And These Are Regulated
under The Emergency Planning and Community Right to Know Act and We\'re
Going to Cover That Today. So That\'s Going to Be One of the Focuses.
Now, You\'ve Noticed That I\'ve Drawn the Circle for Ehs, or Extremely
Hazardous Substances, That Kind of Is Inside the Hazardous Substances
and Outside. That\'s Because Some of the Commodities That Are Extremely
Hazardous Substances Are Also Hazardous Substances, but Some Are Not.
The Last Set of Materials That I\'ve Introduced to You Are Nonhazardous
Substances That Are Otherwise Regulated and There Are Lots of These. But
the Primary One That You\'re Concerned with Is Petroleum. Petroleum Is a
Highly Regulated Material, but it Is Not Considered a Hazardous Material
Under CERCLA. Now, I Wanted to Continue with Schematic to Further
Illustrate How Complicated this Is and How It ‑‑ Important it Is to
Correctly Categorize this Material. You Might Remember That Last Week in
Speaking of Petroleum When We Talked about Underground Storage Tanks,
and We Used the Acronym Usts, the Petroleum Is Regulated under the
Underground Storage Tank Rules Which Are Under the Resource Conservation
And Recovery Act. In Future Modules We\'re Going to Be Talking about
Further Regulation of Petroleum under The Clean Water Act in Particular.
So That Was a New Set of Commodities, If You Will. Now, We\'re Going to
Introduce Two Other Sets of Commodities Today under EPCRA and Those Are
Hazardous Chemicals and Toxic Chemicals. . Now, Again, Each One of These
Sets of Commodities Has a Particular List That\'s Associated with it and
They Have Particular Rules That Are Associated with Them, and Both Of
These Come under the Purview Of EPCRA. So We\'re Going to Be Covering
Those Today. . Now, Keep in Mind That the Reason That It\'s Important to
Correctly Categorize All this Material Is That There Are Different Rules
That Are Associated with Those Materials, And If You Fail to Correctly
Categorize Them, Then You Fail To Apply the Correct Rules, You Are Going
to Be in Violation of The Law. All Right. With Those Thoughts in Mind,
What I Would like to Do Is Turn To the Emergency Planning and Community
Right to Know Act or EPCRA. EPCRA Was Passed in 1986, and it Had its
Beginning in a Very Tragic Event in Bhopal India in 1984. As You Can See
in this Photograph, There Was a Pesticide Manufacturing Plant in Bhopal
That Released a Deadly Gas Called Methyl ‑‑ Mic. It\'s Made in the
Manufacture of Certain Pesticides. This Gas When it Was Released
Outright Killed Several Thousand People in That City, and Even to This
Day Has Resulted in Tens of Thousands of Further Deaths and Disabilities
Because of the Inhalation of It. That Deadly Event Received Worldwide
Attention and as a Result, Congress Decided That Here in the United
States That Our Citizens Ought to Have a Right to Know What Types of
Chemicals They Might Be Exposed To from Industrial Operations in Their
Communities and That We Ought to Be Engaged in Emergency Planning to
Take Care of Potential Releases. So as a Result of That, Congress Passed
EPCRA to Accomplish Those Two Purposes, Give People a Right to Know and
to Do Emergency Planning. Ok. Now, Before Ken and Frank and I Get into
the Details of EPCRA, I Thought it Would Be Kind of Fun To Go a
Knowledge Assessment to See What You Happen to Know About this
Particular Law and Remember We Are Just Focusing in On EPCRA Right Now.
So What I Would like You to Do Is Look at You Are Downloaded Material.
You Should Find There a Knowledge Assessment Maybe Labeled Number 1 for
this Module And I\'m Going to ‑‑ If You Didn\'t Get a Chance to Download
That, I\'m Going to Put the Four Questions up on the Camera Here So That
You Can Review Those and Let Me Do That Right Now. I\'ll Quickly Run
Through These And Then I\'m Going to Put Them Back up on Camera and Give
You a Couple Minutes to Go Through and Answer the Questions. The First
Question Is: Name the Six Notification or Reporting Requirements under
the Emergency Planning and Community Right to Know Act. I\'ll Put These
Back up in a Moment. Second Question: Sit True or False? EPCRA Requires
Development of Emergency Plans by Federal Facilities. The Third
Question: EPCRA Requires the Development Of Local Emergency Plans by ‑‑
We Need to Know Who the Plans Are Developed By. Then the Fourth Question
Is a Multiple Choice. It Asks You to Mark All of the Following That Are
True, and Here Are the Choices for That. So What I Would like You to Do
Now Is to Use Your Downloaded Material and I\'ll Flash These Questions
Back up on the Screen If You Don\'t Have Those. Go Through and Mark
These and Do The Best You Can. How Did You Do? Instead of Waiting until
the End, Why Tonight We Go Through These Now ‑‑ Why Don\'t We Go Through
Now and See How You Did. This Is a Tough One. It\'s a Little Harder than
Some Of the Other Learning Assessments We Had. I Wonder If Instead of Me
Going Through These If Maybe We Could Ask Some of the Participants to
Ask Some of the Questions. So on Number 1 Here, Name the Six
Notification Reporting Requirements under the Emergency Planning and
Community Right to Know Act, Who Can Give Me One of Those? Or All of
Them? We Have Somebody on the East Coast That Could Answer That?
Somebody Anywhere in the United States That Could Answer That? All
Righty. Let\'s Review These. I ‑‑

Caller: this Is Chris from The National Lakeshore and One Of the Things
That\'s Important Is to List the Chemicals That Are Being Used at That
Particular Workplace.

M. Thrasher: All Right. List of Chemicals at the Workplace. That\'s a
Great Answer. I\'m Going to Tell You Throughout This Program the Other
Instrictors and I Are Going to Emphasize the Importance of Having an
Inventory of Chemicals, Because You Cannot Get Started on this Stuff
Without a Good Inventory of Your Chemicals and What\'s in Them. Who Else
Has Something Else? Anybody? It\'s Pretty Hard to Remember All Six of
These, and If You Haven\'t Been Acquainted, It\'s Hard to Know Any of
Them. Let Me Just List These up Here For You. Chris Is Absolutely
Correct on One of the Elements of What We Need to Do. But the
Notification/reporting Requirements, the First One Is The Emergency
Planning Notification. We\'re Going to Be Covering That In Detail Here
in a Moment. The Second One Is the Facility Emergency Coordinator
Notification. The Third Requirement Is for Emergency Release Reporting.
The Fourth Requirement Is for Material Safety Data Sheet Submissions the
Fifth Requirement Are Material Safety Data Sheet Inventory. And So When
Chris Talked about Lists of Chemicals, Certainly He Was Hitting on this
Fifth Requirement Here and Quite Frankly, He Was Hitting on a Couple of
Others Here as Well. And the Last Requirement Is for What\'s Called a
Toxic Chemical Release Reporting. Toxic Chemical Release Reporting. One
of the Things That this Brings out That I Wanted to Mention about All of
These Programs Is That a Lot of Us Think That These Environmental
Hazardous Materials Responsibilities Come Naturally To Us or Just Occur
Because They Make a Lot of Sense and Yet When You Look at a Lot of These
Details You Realize That There\'s A Lot of Detail That You Can\'t Just
Intuitively Know. You Have to Have Training on Them. Thanks, Chris, for
Helping out On That One. Let\'s Look at Number 2 Here. True or False\...
EPCRA Requires Development of Emergency Plans By Federal Facilities?
Somebody in California Know That One? Does EPCRA Require Plans by
Federal Facilities? Who Has an Answer to That One? You\'ve Got a 50/50
on this One. Why Doesn\'t Somebody Take a Chance? No Risk Takers out
There Today. All Righty.

Caller: Hello, Are You There?

Yes, Go Ahead.

Caller: this Is Darrell Barnes in Worland Field Office, Wyoming. We
Think That\'s True.

T. Garrett:

M. Thrasher: and Why Do You Think It\'s True?

Caller: Because the Federal Government Isn\'t Exempt.

M. Thrasher: All Right. Because the Federal Government Is Not Exempt
from EPCRA. That\'s Absolutely Correct. Unfortunately, the Answer to
This Question Is False. Thank You for the Try, Though. You Had a Great
Reason for It. The Reason That It\'s False Is That EPCRA, the Law
Itself, Federal Facilities Are Subject To It, but it Does Not Require
Emergency Planning by Federal Facilities. We\'re Going to Be Going into
That. It Requires Emergency Planning By Local Emergency Planning
Committees, Which Are Community‑based Groups, Not the Federal
Facilities. So Kind of a Trick Question, but Appreciate Your Thinking
about That. You Had Some Good Thoughts. Let\'s Look at Number 3 and I
Just Gave You the Answer to It. EPCRA Requires Development of Local
Emergency Plans By\... Of Course, I Just Told You, It\'s Local Emergency
Planning Committees. Now, These Committees May Have a Federal Agency
Person on Them, But It\'s the Community Group That Has to Do the
Planning. Let\'s Go to the Last One and This One\'s ‑‑ this One\'s
Tough. EPCRA\'s Intended and We\'re Looking for All the Correct Answers
Here\... First, to Provide Public Access To Certain Information
Concerning Hazardous Wastes Present in the Community. Who Has an Answer
to That One? Somebody up in Alaska, Do You Have an Answer to That One?
Just Push the Push‑to‑talk Button. Let\'s Go Through This. It Provides
for Public Access to Certain Information Concerning Hazardous Wastes in
the Community. Now, this Is Kind of Tricky, but I Want to Get You Tuned
into Listening Very Carefully and Critically to the Topics. Because this
Talks about Hazardous Wastes. Remember Earlier When I Showed You the
Schematic That the Emergency Planning Community Right to Know Act
Doesn\'t Cover Hazardous Wastes. It Covers Extremely Hazardous
Substances, Hazardous Chemicals And Toxic Chemicals. So That One Is Not
Correct and Should Not Be Checked. Number Two: Provide for Employee
Access to Chemical Information. Again, That Is Incorrect. This Law Is
Focused on Information to the Community. Community Right to Know. It\'s
Not Focused on Employee Access to Information. That\'s Covered under the
Occupational Safety and Health Act. Number 3, Provide for Development of
Emergency Response Plans by Certain Facilities. Again, Kind of Tricky,
but We\'ve Covered This. It Doesn\'t Have Anything to Do With
Development of Plans by Facilities. That\'s Covered by Other
Requirements. This Is Done by Local Community Groups. The Last One ‑‑ or
Second to the Last One: Provide for Public Access to Certain Information
Concerning Hazardous Chemicals Present in the Community. See What We\'re
Looking for Here? Hazardous Chemicals. Absolutely. That\'s the Focus of
EPCRA. So That One Should Be Checked. And the Last One, Provide for a
Local Emergency Planning by Local Emergency Response Committees or
Planning Committees. That One Is Absolutely Correct. The Focus Is on the
Community Group. Hopefully You Did Pretty Well on That, but I\'m Going
to Tell You, It\'s Hard. EPCRA Is a Very Difficult Statute. If You
Don\'t Have Any Knowledge Of It. But after We Go Through It, I Think
You\'ll Get a Good Sense What You as Managers Need to Know. With That,
Let\'s Dive Right into EPCRA. First Thing I Want to Mention Real Briefly
Is What the Purposes for EPCRA Are. EPCRA Has Two Basic Purposes: One Is
to Provide Public Access To Certain Information Concerning Chemicals in
the Community. And the Second Purpose Is to Provide for Emergency
Planning By Community Groups Called Local Emergency Planning Committees.
When Congress Passed This, They Decided Those Were the Two Purposes, but
They Also Established a System Whereby These Purposes Could Be Carried
Out. And They Set up a Two‑tier System. The First Tier Are What Are
Called State Emergency Response Commissions, Sercs. State Emergency
Response Commissions Have Four Basic Purposes. The First Is to Designate
Emergency Planning Districts. Now, in Most States, Those Districts
Conformed with the Counties in Each State. So Originally in Colorado We
Had 63 Counties, We Had 63 Emergency Planning Districts. But the Law
Didn\'t Require That. So We Do See Some States, like Rhode Island and
Oregon, That Established the Entire State as An Emergency Planning
District. So They Only Have One in Those States. And I Believe
California Established Their Planning Areas For Which They Have Six, So
You See Six Emergency Planning Districts in the State of California.
Unless They\'ve Changed That Since I Last Found out about It. So as You
Go from State to State, Realize That the States Have Established These
Systems a Little Bit Different, but They Have Some Commonality. All
Right, the Second Purpose of The Sercs Is to Appoint Local Emergency
Planning Committees And These Are People from the Community That Are
Going to Be Involved with the Emergency Planning, and it Very Well May
Be That It\'s Appropriate for You To Have a Federal Employee
Participating on That Process. The Third Purpose Is for Them to
Supervise the Local Committees And Then to Handle Public Information
Requests That Come In from the Public So You Can Disseminate the Right
to Know to The People. Let\'s Turn, Then, to the Second Tier That
Congress Set Up, and These Are the Local Emergency Planning Committees.
They Have Two Basic Purposes: Number One Is That They Are to Prepare the
Local Emergency Plan As Required under Section 303 And Then They\'re
Also to Require ‑‑ Handle Public Information Requests That Come In.
That\'s an Overview of the System That Was Established by Congress, and
Now We Need to Look Into, Well, How Do We Get This Information to the
State Commissions and to the Local Committees So That They Can Carry out
These Functions? In Order to Do That, Congress Set up Six Different
Notification/reporting Requirements That Certain Facilities, Including
Federal Facilities V to Follow. All of These Requirements, I Think the
Folks in Wyoming Correctly Identified, Apply to Federal Facilities. The
First Type of Notification Is the Emergency Planning Notification. The
Second One Is Facility Emergency Coordinator Notification. The Third One
Is the Emergency Release Notification. The Fourth One Is the Msds
Submission Requirement. The Fifth One, the Msds Inventory Requirement.
And Finally, the Toxic Chemical Release Reporting Requirement. Now,
We\'re Going to Be Going Over Each One of These in a Little Bit of
Detail During the Program. Now, Interestingly, for Those Who Are
Involved in Transportation or Storing Materials for Transportation,
EPCRA Excludes All of Those Particular Requirements. So What I\'d like
to Do Now Is Get into Those Six Requirements And Turn to Frank to Talk
about The First Emergency Planning Notification Requirement.

F. Mills: Ok, the First Planning Notification Requirement Is Exactly
That, the Emergency Planning Notification. Now, I Would like All of You
to Recognize That Many of You Are Going to Be Sitting on These Lepcs as
Members of Your Local Community. And You Should Actively Seek out The
Head of the Lepc and Ask Whether or Not You as a Federal Agency Employee
or as a Supervisor or Someone Associated With a Large Employer in That
County Should Participate in This Planning Process. Now, One of the
Things That We Would like to Note Is That Whenever You\'re Making These
Reports, You Have to Look on a List of Chemicals Which Are Found in
Friday Cfr Part 355. This Is Different from Other Lists in That this Is
a List of Specific Chemicals, Not a List Of Products. For Instance,
Gasoline Would Not Be on this List, but the Chemical Constituents of
Gasoline, for Instance, Benzene, Might Be on the List. Now, There Are
about Roughly 300 To 360 Chemicals on the List, So It\'s Not an
All‑exhaustive List And You Need to Look at Each Individual Thing. Now,
What You Have to Do Is Make A One‑time Notification to Your Lepc and
Your State Emergency Response Commission in Writing. That Means That You
Need to Look At All of the Chemicals That You Have on Your Facility,
Make a List of Those Chemicals, Check Against the List in 355, and Then
See If You Meet What Is Known as a Threshold Planning Quantity. Each of
the Chemicals Has an Amount in Pounds Listed next to It. This Amount in
Pounds You Need To Convert and See If You Have Those Chemicals in That
Amount On Your Facility. For Example, Let\'s Say That You Had Lead
Batteries Stored on the Facility. Then How ‑‑ What You Would Have To Do
Is Look at the Msds for The Lead Battery, Determine If The Chemical, for
Example, Sulfuric Acid, Is on the List. Now, Sulfuric Acid Is on the
List, So Now You Have to Determine How Many Pounds of Sulfuric Acid Are
Stored in the Batteries on Your Facility. And You Do That by Using a
Simple Calculation That\'s a Part Of the Law, and it Will Tell You How
to Calculate the Amount of Pounds. If You Exceed the Threshold Planning
Quantity for Sulfuric Acid, Which Is 1,000 Pounds, Then You must in
Writing Send That Report to Your State Emergency Response Commission And
the Local Emergency Planning Committee. That Tells Them That These
Chemicals Are on Your Facility And There Are in Case There Is An
Emergency. Now, Each of These Things, There\'s Some Commonality Things
You Might Have in Your Facilities. For Instance, Paints. Paints You Need
to Look at Lead In the Paint, Toluene in the Paint and Other Parts in
the Constituents and You Find That In the Msds. Pesticides, Another Area
Where Pesticides Are Listed in These 360 or So Chemicals. You Need to
Find Out, \"Do My Pesticides Contain One of These Materials?\" There Are
Many Other Products But What You Need to Know Is in The First Reporting
Requirement, You must Report in Writing and You must Send the Report to
the State and to the Local Emergency Response Planning Committee. Now,
Martin, I Think That Pretty Much Handles That Part.

M. Thrasher: and I Think You Did a Good Job of Reemphasizing What Chris
Had Mentioned Earlier, That the Way to Get Going on this Is to Get an
Inventory of the Materials You\'ve Got on Hand, and Then From There
Figure out What the Constituents of That Inventory Is. I Just Want to
Briefly Mention In the Second Requirement, and That Is That If You Are
Required To Report under Section 302 That Frank Just Talked about That
You Must Appoint a Facility Emergency Coordinator, and That\'s a Person
That Is Going to Participate in the Emergency Planning Process with the
Local Emergency Planning Committee. That\'s the Second Requirement. The
Purpose of this Course Is So That You Can Participate in That Planning.
With That, Frank, Do You Want to Take Care of the Third Requirement
Relating to Release Reporting?

F. Mills: Yes, I Will. Now, Here We Are, the Third Requirement. Now,
It\'s Pretty Interesting That this Third Requirement Goes Back into Our
Training to a CERCLA and What They Have Said Is That If You Have a
Material And a Chemical That\'s Listed on These Reports That You Had to
Send to the State or Your Local Committee, and That Chemical Is A CERCLA
Substance, Which We Talked about in Module 1, Then You must Report
Immediately to Your Local Committee and the State Commission If You Have
a Reportable Quantity Release. Now, this Reportable Quantity Is On the
CERCLA List. For Instance, If You Had a Release of Cyanide, the
Reportable Quantity Is One Pound. And Can That Show You How You Have to
Get Back into Another Section of Law How to Determine Whether or Not You
must Report. Now, this Report must Be Made Immediately Orally. So That
Means If We Go out and We Notice a Spill, We\'ve Got to Immediately Pick
up the Phone, Call Our State and Call the Local, and Then We Have a
Situation Which Is Called a Follow‑up Notification. As Soon as You Can
after You\'ve Made Your Oral Report and the Event Has Been Taken Care
Of, You\'ve Cleaned up the Spill, You Then must Report to Both of the
State and Local Committees in Writing and this Report You Have To Detail
Exactly What You Did To Take Clean ‑‑ Clean up the Spill. If Anyone Was
Hurt by the Spill, How Much it Cost. There Are a Lot of Details They
Want to Know, and These Details They Take in Order to Help Facilitate
Planning for Future Spills. Martin?

M. Thrasher: All Righty. Frank, I Think with That What I\'m Going to Do
Is Turn to Ken To Talk about the next Requirement.

K. Morin: All Right. The next Requirement or the Fourth Notification
Requirement Is Related to What the First Caller Said with the Answer.
It\'s Your Inventory of Your Chemicals. What I Want to Address First Is
When Is it Applicable to You? Now, the Most Important Part About this
Inventory Requirement Is the Material Safety Data Sheets. I\'m Going to
Put an Example of One Here on the Elmo. This Is Not an Actual Msds
Sheet, but it Highlights the Information That Has to Be on It. Of
Importance to ‑‑ the Reason Why You Have to Submit These to Your Local
Emergency Planning Committee and Your Local Fire Department Is Because
of the Information on It. It Has Physical Data on the Material That You
Have Stored There. What Is its Flash Point? What Vapor Pressure Does it
Have? It Also Has Fire and Explosion Hazard Data on It. It Has the
Health Hazards, the Personal Protective Equipment Someone Should Wear
and How Do You Respond to a Spill or a Leak? Now, Everything about this
Fourth Notification Requirement Is Very, Very Similar to Osha\'s Hazard
Communication Standard or The Worker Right to Know under Osha. Which
Also Requires You to Have Msdss. That\'s How You Get Tied into This
Regulation. The Way Epa Defines a Hazardous Chemical Is They Actually
Say That If You Are Required to Have An Msds for the Hazardous Chemical,
You Have to Report it To Your Local Emergency Planning Committee and to
the State Commission If You Exceed a Threshold Limit. So How Are You
Going to Do This? As with All ‑‑ You Have to Have That Inventory. Once
You\'ve Maintained ‑‑ or Established That Inventory and You\'ve Come up
with Relative Estimates of How Many Pounds You Have of Each of the
Hazardous Chemicals, You Have to Go Back To That List in Friday ‑‑ 40cfr
And Identify Which of Those Chemicals Is an Extremely Hazardous
Substance. Then You Have to Compare Your Estimated Weights to the
Regulated Quantities for Both The Hazardous Chemicals and the Ehss. Ehss
Are a Subset of Hazardous Chemicals in General. Now, for Every Hazardous
Chemical That You Have That Exceeds a Minimum Threshold Level, You Have
to Submit an Msds to the State Commission and The Local Emergency
Planning Committee. So What Are Those Minimum Threshold Levels? For
Hazardous Chemicals in General, It\'s 10,000 Pounds. And What You See
Here, Pictured Here, Are 50‑pound Containers of A Fire Retardant, And,
Yes, We Have Msdss for Those and If You Are Storing More than 10
Thousand Pounds of That, this Is One of the Chemicals You Would Have to
Report to the Local and State Committees. Now, the Threshold Limits for
Ehss Are 500 Pounds or the Threshold Planning Quantity. Its Tpq. This Is
a Picture of Chlorine Gas. The Threshold Planning Quantity For Chlorine
Is 100 Pounds. Which Is Why I Put it up Here. If You Have a Water
Treatment Plant at Your Facility and You Are Using Chlorine Gas, a
Single Gas Cylinder Weighs 150 Pounds. So You Are Going to Be Subject To
this Requirement of Having to Notify the Local Emergency Planning
Committee of this Chemical. Now, I\'m Just Going to Quickly Go over Some
Examples of Common Hazardous Chemicals That Were Found During Audits at
Land Management Agencies. Cement, Concrete, Is One of Them. The Silica
Dust in Concrete Is An Inhalation Hazard. Msdss Are Required. It\'s Easy
to Get over 10,000 Pounds of Concrete. This Is Cca Lumber, or Copper
Chromium Arsenic Lumber. Last Week Epa a

Announcer:ed with the Wood Preservatives Association That They Will No
Longer Be Making Cca Lumber in the Future. They\'ll Use Other Chemicals
That Are less Hazardous but They Will Still Have Some Chrome or Some
Copper or Some Arsenic, but it Will Be Much Lower Levels. If You Look at
the Msds for this Material, under the Fire Hazard It Will Say That this
Material When Burning Gives off a Toxic Gas. For Obvious Reasons the
Local Fire Department Would Want to Know about That. So If You Have
10,000 Pounds of Treated Lumber, You\'re Going to Need to Submit to That
Your Local Emergency Planning Committee. Now, Diesel Fuel and Gasoline.
There Are Some De Minimis Exemptions under this Regulation. Diesel Fuel
Does Not Have Enough Of Benzene in it or Any Other Hazardous Chemical
Identified by Epa. So, Therefore, You Don\'t Have to Report on Diesel
Fuel. But Gasoline Does. Gasoline Is about 2% Benzene. If You\'re
Storing it in a Quantity Greater than 1600 Gallons, You\'re Going to ‑‑
You\'re Subject to the Submission Of Msdss to Your Local Emergency
Planning Committee. At Most of Our Fire Stations These Vaults I Have
Pictured Here Do Not Have ‑‑ They\'re Typically a Thousand Gallons, But
If You Have a Full‑blown Tank Farm of Gasoline or Other Fuels, You\'re
Probably ‑‑ You\'re Going to Have to Submit Msdss to Your Local
Emergency Planning Committee. Propane Is Another Common Product That We
Typically Find. And the Threshold for That Is Approximately 2400 Gallons
of Propane Will Exceed 10,000 Pounds. Now, in Some States, Though,
Heavily Populated States, like California, They\'ve Reduced Their Limit
for Notification Down to 500 Pounds. So Any Hazardous Chemical Stored
Above 500 Pounds in California Is Reportable. You Need to Submit Msdss
to Their Local Committees. Oregon Has Reduced That Level to Six Pounds.
Last but Not Least Are Tanker Bases. The Liquid Retardant That\'s Stored
in These Bulk Containers Here Is a Hazardous Material as Well. These
Tanks Typically Are 10,000 Gallons Apiece, Well over the 10,000 Pound
Threshold and These Would Have to Be Reported to the Local Emergency
Planning Committee. How Are You Going to Do That Reporting? You Have to
Commit What\'s Called A Tier 1 Form and the Tier 1 Form, You Just List
Hazard Types. You Don\'t Have to List the Product Name for Every
Chemical. They\'re Grouped on Acute Hazards, Acute Health Hazards,
Chronic Health Hazards and Fire Hazards. You Croup Your Chemicals and
You Put Total Weights for Each of Those Groupings. You Have to Submit it
to the Serc, the Lepc and the Local Fire Department and That\'s Supposed
to Be Done Before March 1 of Each Year. If There Aren\'t Any Questions
on That, I\'ll Turn it over to Martin to Continue. Are There Any
Questions on How You Would Do That Reporting?

M. Thrasher: Great. You Know, There Are Two Things You Brought up That I
Just Want To Mention Briefly. One of the Things Is to Keep an Eye on
Your State and Local Requirements Because a Lot of These Local Agencies
Have Taken Ahold of the Federal Law That We\'re Outlining Here and
They\'ve Altered it in Someway and So We Need to Keep an Eye on Those.
The Other Thing Is about the Material Safety Data Sheets, Msdss Are a
Device or a Document That\'s Used under EPCRA Quite a Bit, but It\'s
Used in Other Areas as Well and Two Weeks from Now in Module 4 We Are
Going to Be Covering Material Safety Data Sheets in Detail under the
Occupational Safety and Health Act. So They Have Lots of Uses. Fran, I
Will Turn to You to Ask You to Outline the Msds Inventory Requirements.

F. Mills: We Also Have Another Reporting Requirement Within the EPCRA
Regulation and That Is What Is Known as the Msds Inventory. Now, the
Msds Inventory Is Fairly Unique in That this Regulation Gives You Two
Ways to Report the Information. One, You Can Compile the Msdss And Send
Them Directly as an Inventory of Msdss to Your Local And State Offices.
Or You Can Follow a Specific Format, Which Is Outlined in the Rule,
Which Allows You to List Each Chemical by Name or Common Name of the
Product. And in Doing So, You Can Actually, If You Do Not Have an Msds
or Have a Product You\'re Having a Hard Time Getting One For, You Can
Actually List this Following That Outline in the Law. Now, this Is Very
Important Because Each of These Organizations Compile These Lists of
Chemicals Around the Community, and That\'s How They Determine How Much
Fire Support They Need, Whether or Not They Need to Ask for Increased
Taxes For Haz‑mat Response or If They Have a Chemical Which Might
Require an Evacuation Radius From a Certain Facility. And You Can See
That If You Had A Material Such as Chlorine and You Were Four Miles Away
from Another Facility Which Had More Chlorine, and That an Event Of,
Say, in California Where You Had A Catastrophic Event Such as an
Earthquake, the Local Community Would like to Know, What Would Be the
Worst Case Scenario If All the Chlorine Released at One Time? How Would
We Evacuate and Where Would We Evacuate? And Each of These Little Pieces
Of Information Add up in this Inventory to Allow the Local Committees to
Make These Determinations for the Safety of The Public. Ken, If You
Could Carry on from Here.

K. Morin: Thanks, Frank. What I Want to Talk about Now Is Release
Reporting. This Is Different from That Third Notification That Frank
First Talked about When We\'re Talking about Emergency Release
Notification. Release Notification I\'m Talking About Now Is for the
Normal Spills or Releases to the Atmosphere That Occur When You\'re
Transferring a Product. To Be Subject to this Reporting Requirement, You
Have to Be What\'s Called a Covered Facility. To Be a Covered Facility,
You Have to Have 10 or More Employees and You Have to Manufacture or
Otherwise Proceed To Say 25,000 Pounds of a Toxic Chemical. That\'s
Critical. You Have to Meet Both of These To Be Subject to this Reporting
Requirement. If You Do, Then All of Your Releases, Your Spills That May
Occur, Leaks from Valves, Have To Be Reported from a Form R. To the
Local Emergency Planning Committee, to the State and to Epa. We\'re
Required by Executive Order 13‑148 to Do the Submission. You Are
Thinking, Hay We Don\'t Do Manufacture Anything. In General, That\'s
True. Tanker Bases Are the Only Facility That Can I Think Of, And Frank
Do You Agree with That?

F. Mills: I Will Agree.

K. Morin: among Land Management Agencies That Meet The Definition of a
Covered Facility and Not Every Tanker Base Does Meet This. So I Want to
Talk about How or Why a Tanker Base Would Be Subject to the Standard.
The Mtdc Is the Missoula Technology and Development Center. They Have
Calculated Threshold Volumes for the Amount of Retardant a Tanker Base
must Pump into Air Tankers to Be Subject. When a Tanker Base Is Using
Their Concentrated Retardant and They Mix Witness Liquid, They\'re
Actually Creating Ammonia. That\'s One of the Chemicals Listed in You
40cfr 355. What Mtcd Has Done Is Calculated How Much Ammonia Is Created
When It\'s Being Mixed, and Epa Considers That Mixing of Liquid With
Concentrated Retardant to Be Manufacturing of Ammonia. As I Said, They
Have Calculated Threshold Volumes. In General That Volume Is Right
Around a Million Gallons. For Some Retardant ‑‑ It\'s Around a Million
Gallons. If a Tanker Base Pumps More than A Million Gallons of Retardant
Into Aircraft, Then a Form R Report Is Required for All of The Releases
from That Facility. The Releases Come from Washing Down Aircraft. You
Can See the Staining on this Apron Going into the Storm Drain. And What
Mtdc Has Done Has Come Up with Estimates of What Their Releases from a
Tanker Base and Epa Has Accepted These Estimates. So They Know What\'s
Happening Out There. And It\'s a Quarter Gallon for Spills Occurring
During Loading, You Know, When the Hoses Are Disconnected from the
Tanker, It\'s Estimated a Quarter Gal Sun Released. Then Two Gallons
During Aircraft Washdown. I Bring These up Because If Your Facility
Looks like this and It\'s Discharging into an Earth Ditch, You Can See
the Red Stain, That\'s from the re Tar Didn\'t, but the Blue Stain along
The Edge of the Ditch Is Cyanide. And. There\'s a Program Throughout BLM
And the Forest Service, Tanker Base Upgrade Program, and Facilities Have
‑‑ Are Being Upgrade to Do a New Standard Design Developed by the Forest
Service. Here\'s a Better Picture of Some Of the Cyanide Staining We
Have Been Seeing Doing These Audits. If You Have this Occurring at Your
Tanker Base, You Need to Be Getting with Your Engineers and Your State
Fire Manager or Your Regional Fire Manager to Get on The Tanker Base
Upgrade List, Because Unlined Lagoons Receiving the Tanker Base Runoff
Are Not Permitted under Most States. They Have to Look Something like
This. This Is What You Should Be Going To, Is to a Lined Lagoon. So Who
Does this Reporting for You? Unfortunately, this Is One ‑‑ Fortunately
this Is One of the Easy Ones to Comply With. If You Keep Good Records
and You Submit Them to the Mtdc or the Missoula Technology &
Developmenment Center, They Will Prepare the Form R for You. For BLM
They Prepare Them All And Send Them down to Nfc That Goes Through and
Submits Them to Epa. Any Questions Related to the Form R Reporting? .

M. Thrasher: All Right. As You Can See, EPCRA Is Pretty Complicated in
Terms of its Six Requirements and I\'m Sure Some Of You Are Sitting
There Saying I Have Never Even Heard of this Before, and If That\'s the
Case, Our Recommendation to You as Managers Is to Either Access Your
Professional Staff or to Get the Resources, Come in and Do an
Evaluation. Quite Frankly, it Sounds Pretty Daunting to Start With, but
Once You Get ‑‑ Once You Do Your Inventories, as Chris Suggested Earlier
O and You Figure out the Constituents of Those Inventories and the
Releases to The Environment and So Forth, It\'s Going to Become Pretty
Routine Compliance with EPCRA. I Would Really Encourage You to Use Your
Push to Talk or Fax in Some Questions at this Time Because We\'re Kind
of Concluding The Discussion about These Six Requirements. We\'d Love to
Have Questions from You about It.

Caller: I Have a Question.

M. Thrasher: Yes? Go Ahead.

Caller: Actually, the Msds Sheets, You Place a Lot of Faith And Hope in
Those Sheets and We Have Found That in a Lot of Cases Those Msds Sheets
Are Incomplete. Some Are Not Filled out at All Or They Don\'t Provide
the Necessary Information, and on Top of That, the Msds Sheet, When
These Are Made out by the Company, for Example, There Is No Requirement
as to Who Fills Those Sheets Out. It Could Be Anything from the
President of the Company down to The Secretary.

M. Thrasher: That\'s an Observation and You Are Absolutely Correct That
the Msdss Are Required to Be Filled Out by the Manufacturer, Sometimes
the Distributor of Chemicals, and You Are ‑‑ You Pretty Well Have to
Rely on What They\'ve Put down on the Msds. So ‑‑

K. Morin: One Other Comment Related to That, for Those Msdss That Are
Inaccurately Filled Out, or You Have No Faith in Them at All, Osha Is
Aware of That Problem, but as it Relates To EPCRA, If You\'re Not
Storing Over 10,000 Pounds of That Material, You\'re Not Subject to This
Regulation Anyway. That\'s Really Important to Keep In Mind. And
Hopefully If You\'re Not Comfortable with That Msds, That You\'re Not
Storing Much of That Material. I Don\'t Know If That\'s True or Not.

F. Mills: and Also I Would Like to Make a Comment That There Are a Few
Databases That Exist on the Websites Where You Can Actually Go in and
Retrieve More up to Date and Better Prepared Msdss. If You\'ll Look in
Your Toolkit, You Should Be Able to Find Some Areas Where They Will
Point You Toward an Msds Site and You Can Actually Research a Product
and Actually See If There\'s a Better Msds. The U.s. Military Also Has a
Compendium of Military Version Msdss and Almost All National Guard and
Army Reserve, Navy Reserve, Air Force Reserve Facilities Have a Copy of
this Compendium, and They Will Be Glad to Help You Research an Msds If
You Need To. So That\'s an Excellent Resource To Get Better Data If You
Have a Poor Msds.

K. Morin: the Website for Msds Is a Great Site. One Is a Great Name. It
Is Run by the University of Vermont and It\'s Called Www.hazard.com. Any
More Questions?

M. Thrasher: I Might Mention That One of the Outfalls of Providing the
Form R Reporting To the Epa Is That They Do Publish a Listing Nationwide
of What They Call Polluters Based On the Form R Reporting, and I Thought
I Would Show You One of Those Here. I Don\'t Have a Current One. On this
Camera ‑‑ Let Me See If I Can Get the Bend out ‑‑ it Says Colorado Ranks
Low for Legal Toxic Emissions, Epa Says. And Then the Article, I\'m Not
Quite Sure If You Can Read It, It Goes Through and Talks about Who the
Biggest Polluters, If You Will, in Colorado Were for The Year 1992. You
Might Notice That the News Article Came out in \'94. The Publish Date Is
Typically About 18 Months after it Is Submitted to Them. But this Sort
of Thing, There Are No Mandatory Requirements, Because You Get Your Name
on This Top of the List, but It\'s Certainly Not Real Good for Your
Public Image and it Kind of Induces People to Reduce Their Emissions of
Even Lawful Pollutants. Any Other Discussion on the EPCRA Six
Requirements, Ken or Frank ‑‑ Frank or Anybody out There Listening? We
Would Be Glad to Answer Questions. All Right. Then What We\'re Going to
Do Is Move on to the next Kind of Challenge for You and Doing the
Knowledge Assessment Number 2. What I Would like to Do Is Just Kind of
Challenge Some of Your Thinking about the Six EPCRA Reporting and
Notification Requirements by Thinking about How They Might Apply to a
Particular Image That We\'ve Got Here. And the Image That We\'re Going
To Set up this Problem with Is An Image of Several Large Gasoline Tanks.
I Don\'t Know the Total Volume, But Obviously There\'s a Lot of Volume
There. What I Would like You to Do Is To Look over the Six Notification
and Reporting Requirements That We\'ve Just Gone over and See How They
Might Apply to These Particular Tanks And the Commodities Within the
Tanks. So Why Don\'t You Take a Couple Minutes and Just Kind of Think
Through That and We\'ll Come Back And Discuss It.

M. Thrasher: Ok. What I Would like to Do Is Get Your Help in Walking
Through This, See You Did as Far as Analyzing the Possibility of This
Six EPCRA Requirements Applying to These Particular Tanks. What I Would
like to Do Is Ask Somebody to Come on and Just Say ‑‑ Give One of Them,
I Don\'t Care If They\'re in Order or Not, And Then Talk a Little Bit
about Why That Particular Requirement Might Apply to this Tank. I\'m
from Montana, and I Wonder If There\'s Anybody in Montana That Can Come
on and Give the First Answer Here. Somebody in Missoula, Please, From My
Old High School in Missoula. How about Anyone in the West Coast? Do We
Have Anybody That Looked As These Six Requirements and Saw How They
Might Apply to Those Tanks? Please Come on Your Push to Talk. What We
Would like You to Do Is Start Thinking as Managers and Analyzing These
Issues to Look At the Requirements and Let Me Just Suggest One to Get Us
Going Here. The First Requirement That Frank Talked about Is the
Emergency Planning Notification. So under That Requirement, as Frank
Described, You Have to Look at Your Extremely Hazardous Substance List
and See Whether Or Not Any of These Commodities Are on That List. Now,
If You Looked up Gasoline On That List, You Would Find That Gasoline
Isn\'t There, but That Would Be a Good Place to Start. After That, You
Need to Look At, Well, What\'s in the Gasoline? And You Have ‑‑ You
Already Know That Gasoline Contains a Lot of Benzene, Which Is a Highly
Regulated Material. So You Then Go into Your Extremely Hazardous
Substance List and Look for Benzene. And If You Did That, You Would Find
it Wasn\'t There. So You Would Exclude That. So in All Probability,
You\'re Not Going to Find That the Section 302 Requirement Applies To
These Particular Tanks. But That\'s the Sort of Analysis You Go Through.
What Would You Do next for the Second Requirement? That\'s the Facility
Emergency Coordinator. Assuming We Don\'t Have to Make a Notice under
the Section 302, Do We Have to Appoint a Facility Emergency Coordinator?
Who Knows That? Somebody in Hawaii or Alaska, Do You Know? Take a
Chance. Ok. Certainly Not. If You Don\'t ‑‑ If You\'re Not Covered by
Section 302, Then You Don\'t Have to Appoint a Facility Coordinator to
Participate in The Planning Process.

K. Morin: Martin I Want to Note Something You Said Before, That in Some
States and California Is the One That Immediately Comes to Mind, Has a
Much Lower Threshold Requirement. It\'s 500 Pounds. So for a Smaller
Volume like We\'re Showing Maybe ‑‑ in Another Tank, They Would Still
Require You to Designate an Emergency Coordinator.

M. Thrasher: Good Point. I\'ll Again Say a Lot of These States Have
Changed the Lists. They\'ve Added Things to the Lists. What We\'re
Talking about Today Are the Federal Rules, and You Need to Keep an Eye
on Those State Rules Because They Do Alter Them on a Regular Basis.

F. Mills: Martin, One Other Thing, Many Times the Lepcs Are Coordinated
by Local Fire Departments and Oftentimes the Fire Department Is Going to
Be Coming to Your Facility Conducting Fire Inspections and That\'s a
Good Time to Get a Person Who Is Well Trained and Versed in this EPCRA
Requirement Because They Receive the Bulk of This Information. So If
Your Fire Department Is Out There Doing an Inspection, Ask Them, Do You
See Anything That We Need to Be Reporting Under EPCRA? Are There Any
Issues That You Need to Know as a Local Emergency Planning Group That We
Should Be Telling You About? These Are Not Onerous Requirements, and
Oftentimes Just Getting a Community Resource out to Talk to Us Can Help
Us Make Some Decisions About What We Need to Report.

M. Thrasher: Absolutely. Absolutely.

K. Morin: That\'s a Good Point, Frank, and for Those of You, Though,
That Are in a Facility or Complex Where It\'s Just Just Volunteer
Firefighters And Maybe Half of Your Staff Is Part of It, You Want to Get
Specialized Expertise. Every State in the Country Has a State Fire
Marshal and I Have Worked with Quite a Few of Them And They\'re More
than Willing to Come out to Your Facility and Tell You What Kind of
Information They Want, How They Wanted it Stored. The Most Critical
Chemical They\'re Interested in Is the Herbicides. They Want to Know
Where They Are On Your Compound and How Much You Have, Because If There
Is a Fire, They Want to Let Those Herbicides Burn. They Don\'t Want to
Try to Put it Out.

M. Thrasher: I Didn\'t Want to Go Through All Six of These Requirements,
but the Point Is Here, What You Do Is You Take Each Requirement by
Itself and You Do an Analysis on That Requirement, See Whether or Not
You Need to Comply with It, And, You Know N this Program We Kind Of Take
Apart a Lot of These Requirements and We Look at Them In Kind of a
Myoptic View Because We Are Just Looking at That Requirement, but as
Frank Just Mentioned, That\'s Not the Way the Real World Runs. We\'re
Doing That for Study Purposes. When You Are Talking with Your Fire
Officials Who Are Really Involved with this Stuff, They Are Going to
Marry up Their Responsibilities under the Uniform Fire Code and Maybe
Even Building Code Requirements, You Don\'t Know, with These
Requirements and They\'re Going To Look at Them All as a Group. So
They\'re Going to Vary Just a Little Bit from Just the Singular View
That We\'re Looking At Here.

K. Morin: That Point on the Different Codes in the Regs Is a Real Good
One, Too. If You Are a Manager 1 an Engineer or Facility Coordinator And
You Are Thinking about Installing Some Fuel Tanks, You Should Be Asking
Yourself, What\'s the Volume I Really Needed to My Job and Compare it To
the Regular Law Story Thresholds. For EPCRA, It\'s Around 1600 Gallons
of Gasoline. For the Clean Water Act for Spill Spill Prevention Control
And Countermeasures, It\'s 1320 Gallons. So If You Can Get Away with
Storing below 1,000 Tow Galens And it Meets Your Needs, You Don\'t Have
to Deal with Two of These Regular Rations. That\'s What We Are Trying to
Do, Is a Raise Your Awareness So You Can Make Intelligent Decisions. If
You Need 2 Thousand Tow Gallons to Do Your Jobs Great, That\'s Why Frank
and I Have Jobs. We Will Make Sure You Have the Things You Need. But One
of the Other Things We Will Try to Do Is Tell You How We Have Lower
Thresholds So We Don\'t Have to Comply with Some Of the Regs. We Still
Have to Have Secondary Containment and Safety Stuff but We Can Get out
of Some of the Reporting Requirements.

M. Thrasher: I Think with That I Will Turn the Program Back over to Tony
for Questions And a Break.

T. Garrett: We Hope You Did Well on That Exercise. At this Point We\'ll
Keep the Green Light Illuminated and Invite You to Use Those
Push‑to‑talk Microphones and Contact Us with Any Questions or Comments
You Have on the Material That We\'ve Covered Thus Far. And Remember,
Those of You Without Push‑to‑talk Technology At Your Viewing Site Can
Call Us Right Now Toll‑free at this Number\.... Or If You Prefer, You
Can Send Us a Fax At\... We\'ll Pause Now for Just a Moment, Give You a
Chance to Check in and Push to Talk. . All Right. While We Wait for
Anyone from Our Viewing Audience to Check in With Us, We Did Receive a
Fax Earlier from Chris in Lakeview, Oregon. Chris\' Question Is: Can BLM
and Forest Service Lands by Themselves Be Considered a Facility? Anyone?

I\'ll Answer That. That\'s Kind of a Technical Question, Chris. The Term
Facility Is Really Kind Of a Funny Word and I Would like To Explain it
to You like This. If I Told You the Sun Rose Before the People and the
People Fell to the Ground and Worshipped, Could You Spell the Word Sun?
Now, Some People in the Audience Would Say S O N and Others Would Say S
U N. The Reason I Use That Analogy Is That the Law Is Written the Same
Way. If We Use a Term \"Facility\" You Really Need to Know the Meaning
Of the Term for the Specific Regulation That We\'re Talking About. It\'s
like That Word \"Sun,\" Facility Can Mean One Thing in One Regulation
and Mean Something Else in Another. That Means That If You Have a Forest
Service or BLM Land in Some Regulations the Entire Land Mass Might Be a
Facility under That Regulation. But in Other Regulations, the Term
\"Facility\" May Only Mean a Particular Building on the Property. So You
Really Have to Be Careful When You\'re Reading the Laws and Reading
Regulations That You Know the Meaning of the Terms Before You Get into
Defining the Term. It\'s Really Important.

T. Garrett: Frank, That\'s Exactly the Way I Would Have Answered Chris\'
Question. Ken, Martin, Any Other Thoughts On That?

M. Thrasher: Well, I Agree With What Frank Said. It\'s Very Confusing.
Most the Time We\'re Looking at a Contiguous Area Owned by a ‑‑ by One
Owner, but Oftentimes We Can Get Subareas Within a Contiguous Land Area
and It\'s Very Confusing.

T. Garrett: Ok. Anyone Else in the ‑‑

M. Thrasher: I Should Mention That Your Hazardous Materials Specialists
and Coordinators and Other Experts at the Centers Can Help You in Each
Individual Case Define What a Facility Is.

T. Garrett: Ok. Thanks, Chris, in Lakeview, Oregon, for Sending in That
Question. And We\'ll Pause Now Again for Anyone Else in the Viewing
Audience to Check in with Us on The Push to Talk, by Telephone Or by
Fax. All Right. We Do Have a Note from the Control Room ‑‑

Caller: this Is Pat.

Caller: Could I Say a Few Words Here?

T. Garrett: Let\'s Get Pat First, Who Checked in First. Pat in the Park
Service, Where Are You Calling From?

Caller: Thank You. I Am from the National Park Service at the Cowpens
National Battlefield That Will Are You Aware of State Sites We Can Go To
Get Their Regulations Related To This?

T. Garrett: We\'ll Ask the Panel. State Sites for Information.

K. Morin: What State Are You In? Pat?

Caller: South Carolina and Specifycally I Was Referencing Websites.

K. Morin: Right. I Don\'t Have a List, but Every Regulatory Agency I
Have Had to Deal with and I Am Dealing with Everything Colorado and
West, Which Do Have a Site of Some Type.

M. Thrasher: Excuse Me. I\'ve Got a Book, When We Come Back from the
Break, I\'ve Got a Book That Was Published in 1999, So It\'s Not Too
Old, That I Think Lists All the State Contact Points for EPCRA. Let Me
Find That During the Break and See If I Can Give it To You after the
Break.

T. Garrett: Pat, We Will Be Checking on That and Get Back With You after
the Break.

K. Morin: More Important than The State Contact, Though, You Need to Be
Aware of Who Your Lepc Is, and They\'re Going to Give You Better
Information on What They Expect from You. So I Would Start There and I
Doubt They Have a Website.

T. Garrett: All Right.

Caller: We Do Work Closely With Our Local Community Planners. I Think We
Have a Pretty Good Handle on That. I Just Thought There Might Be
Something Additional We Needed.

T. Garrett: We\'ll See What We Can Find out During the Break, Pat, and
Get Back with That Question. As You Were Checking in There Was Someone
from BLM Trying to Reach on the Push to Talk, So You May Go Ahead.

Caller: this Is Darrell Barnes Again in Wore Lund, Wyoming. I Wanted to
Ask the Question, I Was a Little Confused with Your Definition Facility.
Correct Me If I\'m Wrong, but We Manage Several Million Acres Here. We
Have a Facility Where All the People and Most of Our Resources For
Working on Public Lands Are Located on a Small Site. Now, to Me That\'s
the Facility, Not All These Millions of Acres Of Public Land.

F. Mills: Well, it Goes Back To What I Said, You Have to Look At the
Individual Regulation or Law That You\'re Addressing When You Use That
Term \"Facility.\" For Instance, under RCRA, RCRA Uses the Term
\"Facility\" to Mean All Contiguous Land That Is Connected Would Use One
Number For All Hazardous Waste Transport and Storage. So in That Term
\"Facility\" Might Mean the Entire Land Mass as Long as It\'s Completely
Connected. Now, We Have Some ‑‑ We\'ve Talked with Regulatory Agencies
Because We Have Some Special Conditions That Exist Within Our Land
Management Function, and They Have Allowed Us Some Variance in the
Terms, But, Really, When You Use a Word like Facility, Always Look at
the Law First and Go to the Definition Section of the Law and in Every
Single Regulation and in Every Single Statute, There Is a Section Called
\"Definition.\" Look up the Term \"Facility\" in Each One of Those and
See What It Says. For Example, a Ship Is a Facility. For Example, a
Bucket under CERCLA Can Be a Facility. So Those Terms ‑‑ You See, That
Word Is a Very Broadly Defined Word. You Have to Be Very Careful That
You Don\'t Transpose the Definition from One Regulation To Another. And
There\'s No One Word \"Facility\" That We Can Use All Exclusively. You
Will Hear Us Say That over And over Again in These Laws, You Have to
Look at the Individual Regulation and Law And Decide How it Applies to
Your Situation. It\'s Not an All‑encompassing Situation.

M. Thrasher: Frank, Let Me See If I Can Illinois Straight That on this
‑‑ Illustrate on That this Camera for a Moment. I Have Depicted Here a
Rather Large Contiguous Land Area of 2 Million Acres and Let\'s Presume
It\'s Owned by Federal Agency. Well, That\'s in Some Respects Is A
Facility. The Entire 2 Million Acres. Because It\'s One Contiguous Land
Area. Now, You May Have a Wareyard Over Here That Only Comprises 10 Or
20 Acres. And in Some ‑‑ under Some Regulations, this Might Be the
Facility. So If You Have Two or Three of Those, You Might Have Two or
Three Facilities. And Then You May Have an Illegal Dump Site over Here
That You\'re Dealing with and in Some Respects That Can Be Dealt with As
a Facility. So You Need to Look at Regulation by Regulation to See
Whether You Want to Deal with The Entire Mass or Deal with These
Separate Sites. .

T. Garrett: Thank You, Martin And Frank and Ken. Any Other Questions
from Our Viewing Audience, Just Go Ahead And Push to Talk and We\'ll Be
Happy to Entertain Those Questions.

Caller: Hello, this Is Worland Again. Steve this Time. Would You Guys
Want to Comment On BLM\'s Requirement or Responsibilities for
Contractors Working on Public Land or the Forest for Their Compliance
with This Law?

K. Morin: Talking about Contractors Running Air Tankers, Steve, Air
Tanker Base Contractors?

Caller: I\'m Thinking More of Laying Pipelines and Things of That Nature
or Doing Work in the Oil and Gas Patch.

F. Mills: Steve, Contractors Are Definitely Responsible under The Law
for Their Own Reporting Under These Requirements. They Actually Are More
‑‑ the Law of More ‑‑ More Definitely Attaches to a Contract Operation
Than it Does to Us Because We\'re Reporting under a ‑‑ an Executive
Order, but the Thing To Remember Is, as a Manager, We Also Have the
Responsibility to The Public as We\'re Managing That Operation to Ensure
That They Are Doing What They\'re Supposed To. Now, I Know a Lot of Our
Contracts Have Very Broad Statements in Them That Say You Will Follow
All Existing Environmental Laws and Regulations. But Courts Have Said
Time and Time Again That We Need to Be More Specific in Directing People
Who Are Using Special Lands and Permits on Our Lands To Follow These
Regulations. So If You\'re a Contract Administrator and You\'re out in
The Area and You Know That There Is an EPCRA Requirement That They\'re
Supposed to Be Making, You Should Make it a Point to Sit down with the
Staff of That Contract Facility and Ask Them, Are You Meeting Your
Requirements under EPCRA? Are You Meeting Those Things? Now, Not That We
Have a Requirement to Do the Report, We Don\'t, but We Need to Make Sure
That They Know We Want Them to Do That Report Because It\'s a Perception
of the Public That If They Make a Mistake and it Hurts People, We\'re
the People Who Oversaw That Operation from the Start. So under the Law
They Have the Responsibility and They Are the Ones That Will Be Held
Accountable Legally, but Then We Have an Oversight Responsibility As the
Manager of the Land Mass.

K. Morin: Steve, One Other Thing, and ‑‑ Are You Dealing With a Lot of
Small Mom & Pop Oil Patch Contractors? Or Are You Dealing with Larger
Ones?

Caller: Both. My Question Was Directed at the Large Contractors and the
Big High‑profile Projects.

K. Morin: Right. And the Mobiles and Exxon and More Staff, They Could
Spend 14 Days Talking about EPCRA. They\'re Very Well Versed in this
Regulation, and They\'re Reporting Millions of Tons of Emissions at the
Refineries, Et Cetera. If the Local Guy on the Pad Doesn\'t Know What\'s
Going On, The Emergency Coordinator for The Region Does and That\'s the
Person I Would Be Talking To.

T. Garrett: Steve, Does That Answer Your Question?

Caller: Yes, it Does.

T. Garrett: Thanks. Anyone Else Now from the Viewing Audience, Park
Service, U.s. Fish

&

wildlife Service, Forest Service, BLM, Anyone Else? Just Push to Talk.
All Right. We Had a Note Earlier That We Had a Little ‑‑ Had a Bad Hum
on One of the Telephone Lines from One of the National Park Service
Sites, and That Was Disconnected. Some of the Nps Offices May Need To
Check to See If You\'re Still Connected to the Telephone Bridge. So
We\'ll Ask You to Do That to Make Sure That You Can Still Get In Touch
with Us. And Maybe You Can Do That During The Break. I Think We\'re
about Ready to Take a 15‑minute Break Now. When We Come Back, We\'ll
Look at Special Pollution Management and Discuss Hazardous Waste Issues.
And after That, East Meets West In Another Round of Our Exciting Game
\"The Hazmat Challenge.\" Lots More to Come after the Break. We\'ll See
You 15 Minutes from Now. (15‑minute Break)

T. Garrett: Welcome Back to Module 3 of Our Six‑part Series, The
Manager\'s Tool Kit for Environmental Compliance and Pollution
Prevention and Pollution. Back for the Second Part of Today\'s Program
Our Lead Instructor Mar Thin Thrasher, Frank Mills from the USDA Forest
Service and Ken Morin from the BLM. Before We Return to the Coursework
We Would like to Mention Some Upcoming Events on The BLM Satellite
Network. One Week from Today, Thursday February 28th, We Will Be
Broadcasting a BLM Course on Safety for Supervisors. Check the NTC
Homepage for Details. Two Weeks from Today, March 7th, We\'ll Be Back
with Module 4 of The Manager\'s Cool Kit Series Covering, Osha, Dot and
Fifra. March 14th We Will Present Module 5 That Will Cover the Clean Air
Act, Clean Water Act, Safe Drinking Water Act and Spill Prevention
Planning. Our Final Telecast in this Series Will Air on Thursday March
21st When We Will Explore Environmental Management Systems And Take a
Look at Your Agency Audit Programs for Safety Health And Environmental
Compliance. And on April 3rd and 4th We Will Be Broad Katzing a Two‑day
Interagency Satellite Course, Contracting Officer\'s Refresher Training.
So If You\'re a Cor and Need to Keep Your Certificate Current, Contact
NTC Right You a to Register for That Course. Again, Consult the NTC
Homepage For Additional Information about Our Program Schedule. Now
Let\'s Turn to Martin Again For a Discussion about Special Pollution
Management. Martin?

M. Thrasher: Thanks, Tony. And Welcome Back. Right Before the Break Pat
in South Carolina Asked for Some Websites from the State Agency Relating
to EPCRA. I Don\'t Have Any Websites Here, But on this Camera I Do Have
a An ‑‑ Name and Address and Phone Numbers for a Contact at the State
Level There for EPCRA Reporting. So Hopefully If You Contact That
Agency, They Can Get You Going In the Right Direction. I\'ll Leave it up
There for a Minute So You Can Have a Chance To Copy That Down. In the
Meantime While We\'re Waiting for Pat to Copy That Down, If Anybody Else
Has Any Questions about Contacts at State Agencies, Please Let Us Know
and We Will Try to Get That Information. I Am Sorry We Couldn\'t Get a
Website for You Right Away.

Caller: Thank You.

M. Thrasher: What I Would Like to Do Is Move into the next Segment of
this Particular Module. The Objective for this Module ‑‑ Or for this
Segment Is That You Will Know What Rules Apply to Special Pollution
Management as Well as Considerations for Making Decisions ‑‑ Certain
Management Decisions. Now, in this Segment We\'re Going To Be Covering
Some Management Of Certain Special Wastes, but Wave We Get into the
Detail of Those Special Pollutants and Wastes, What I Would like to Do
Is Try Again to Challenge Our Thinking about Some of the Rules That
Apply, Some of the Things That We Ought to Be Thinking About in Terms of
Special Pollutants and Wastes Through a Knowledge Assessment Exercise.
Now, in Ordered to This, What Ware\' Going to Do Is to Show a Photograph
of a Wareyard, or a Storage Area, and Then Ask You To Go Through it and
Look for Specific Issues That Come to Mind Relating to Special
Pollutants. So I\'m Going to Give You about a Minute Right Now to Look
for These Particular Issues, Just Jot Them down and Then We\'ll Chat
about Them When You Come Back.

M. Thrasher: All Right. Let\'s See How You Did about Identifying Issues.
I Found in Being in this Business for So Many Years One Of the Hardest
Things to Do Is To Translate the Academic Rules To Real Life Situations,
and That\'s the Challenge for Managers, to See Things and How They Apply
in the Field. . Is There Anybody on the West Coast, Washington, Oregon,
California, Who Came up with Special Issues That You Saw Depicted in
this Picture? Why Don\'t You Do Your Push‑to‑talk and Let Us Know. How
about Anyone West of the Mississippi, Let\'s See If We Can Get Somebody
in Colorado, New Mexico Involved with This. Any Particular Issues, When
You Look at This, Are There Any Issues That Just Come to Mind And You
Don\'t Have to Worry About Being Right about It, It\'s The Issue
Recognition That\'s Important, Not Whether or Not it Actually Comes out
That You\'re Right or That There\'s Actually An Issue There. But It\'s
Recognizing What Are The Possible Issues. Who Has One?

Caller: this Is Chris from Lake Shore.

M. Thrasher: I Missed Your Name.

Caller: It\'s Chris Case with Pictured Rocks National Lakeshore.

M. Thrasher: Ed. Thank You. Go Ahead, Ed.

Caller: this Is Chris Case. Can You Hear Me? I Had Trouble with the
Microphone Last Time. Can You Hear Me Now?

M. Thrasher: Yes. Go Ahead.

Caller: Ok. I See a Couple Things There. One Is That Green Thing in the
Front Possibly Could Be Something, Might Have a Transformer, Pcb, There
Is No Containment Underneath. . It Could Be Releasing and Leaking in the
Ground. The Other Thing Is the Tanks That Are Shown There, They\'re
Unmarked. You Don\'t Know What\'s in Them. It Could Be Something That
May Be Hazardous. The Other Thing Is Is a Tank Sitting Empty Could Very
Well Be Something That Could Count Towards Your Quantities of Petroleum
Storage and That Kind Of Thing. We Don\'t Know What That Tank Was For.

M. Thrasher: Are You Talking About this Tank Back in the Background?

Caller: Right, That One in The Truck. The One in the Foreground, Too,
Looks More like a Pressure Vault, but I Guess That Could Have Been Some
Kind of Tank Also. You Don\'t Know What Kind of Residual Product Is in
There That May Be Leaching.

M. Thrasher: Right. Down on the Bottom.

K. Morin: What about That Tank, Chris? What Would We Have to Do with
That Tank That\'s on the Trailer? What Sort of Requirements May Kick In,
Either EPCRA or Something Else?

Caller: I Guess it Would Depend ‑‑ It\'s So Far Away You Can\'t Tell,
but If There Is Some Kind of Label or If It\'s Unlabeled, If That\'s
Something That Could Be Usable, Then ‑‑ And, Say, for Example, it Was
Even an Empty Fuel Tank, Gasoline Tank, That Could Be Considered as a
Usable Tank and Add to That Threshold Quantity For Reporting If It\'s ‑‑
If It\'s Something That All of a Sudden Could Be Put Back in Use.

M. Thrasher: All Right.

K. Morin: Exactly Right. Let\'s Say, for Example, That Was An Abandoned
Tank and I Was Using it to Hold Gasoline Because I\'m Filling Equipment
With it and it Sits in the Yard For Four or Five Months at a Yard, and
That\'s ‑‑ Let\'s Say It\'s a 3,000‑gallon Trailer.

Caller: Because You\'re Using That for Gasoline, Whether It\'s In Use at
the Time or Not, You Have to Consider That Being Full And Add to Your
Quantities for That Threshold Reporting.

K. Morin: Exactly. This Would Definitely Be Subject To Notifying the
Lepc and the Sec ‑‑ Serc.

M. Thrasher: You Found a Lot Of These Today. We\'re Not Going to
Covering Pcbs Today, but I\'m Glad You Picked Up on That, Any Type of
Electrical Equipment, Particularly Transformers, Can Contain Pcbs and
It\'s a Highly Regulated Special Material. Is There Anyone Else That Had
Any Other Issues That They Saw Depicted Here in this Picture? Was There
Somebody from the Park Service? I Missed Your Name If There Was. All
Right. Let Me Just Point out a Couple Of Others and It\'s Really Hard To
See in These Pictures, but All We\'re Doing for Is Issue Identification.
Did You Know Thinks Device Back Here? I Can\'t Quite Tell If It\'s a
Motor or Part of an Old Boiler, But Whenever You See Something Like
This, Old Equipment like That, You Probably Want to Start Thinking about
Asbestos. A Lot of These Old Devices, Boilers and So Forth, Contain
Asbestos. And in Addition, Let Me See, Back Here, It\'s Really Obscure,
It Looks like a Pile of Pipe and Whenever You See Pipe, Particularly Old
Pipe, it Could Be What\'s Called Transite Pipe, Which Contains Asbestos
Finers. By the Way, the Same with this Type of Equipment Here.
Occasionally They Use an Asbestos Rope Packing in Some of The Flanges
and So Forth to Get A Seal. So You Want to Think about Asbestos. Look
Way Back Here and It\'s Really Obscure in the Background. We See about
Four 55‑gallon Drums, and Immediately Hazardous Wastes, Used Oil Issues
Come Up. So That\'s the Sort of Thing That You Want to Look At. Anyway,
What We Want Managers to Do Is Get a Little More Used to Not Just Seeing
What They\'re Used to Seeing Day to Day but Start Thinking about Some of
These Rules That May Apply to Some of this Material and Determine
Whether or Not You Need to Do Something with It. All Right. Good Job. .
What I Would like to Do Now Is Start this Discussion about Some Special
Pollutants, and We\'ve Got Kind of a Potpourri to Talk About Them Today.
But First, Ken Is Going to Talk About Used Oil.

K. Morin: Thanks, Martin. Used Oil Is Probably the Most Common Hazardous
Chemical That Is Generated at Land Management Agencies. And When We\'re
Doing Audits and I See Heavy Equipment ‑‑ at Some Point in Time I
Realize That We\'re Going to Be Generating Used Oil, and the Heavy
Equipment Operators When I First Asked What Do You Do with Your Used
Oil, \"Oh, We Contract All That Maintenance Out.\" But Invariably Every
Site I Have Been To, Somebody Else Is Generating Used Oil Once in a
While Whether it Be Maintaining Snow Machines or When They\'re Doing
Maintenance, They\'re Working Way out in the Boon Ease, it Took Them
Four to Five Ours out There and They Decided They Need to Change the
Hydraulic Oil. They Are Generating Used Oil. What We Are Going to Go
Through Today Is How to Manage That Used Oil. So When You See Storage
Sites Like this and I Showed You a Picture of this Last Week, Thanks
Poster Oil on How Not to Store Used Oil. I Want You to Be Able to
Identify What\'s Wrong. I Will Go Through Those Management Issues. The
Point I Made Last Week about Used Oil Was If That If It\'s Recycled,
It\'s Not a Hazardous Waste. But That Doesn\'t Mean There\'s No Other
Regulations Associated With it Because Epa Has a Variety of Regs on How
You Have To Properly Store it and the Condition of Those Container and
Those Regs Are Found in 40cfr 279 Subpart C, Management Standards for
Used Oil. So Who Is Subject to These Regulations? Unlike Hazardous Waste
Regulars, Oh Most, for Example, to Be Regulated under RCRA, You Have To
Generate More than ‑‑ to Be Fully Controlled under RCRA, You Have to
Generate More than 100 Kilograms a Month. To Be Regulated as a Public
Water Service System You Have to Serve Water to More than 25 Individuals
More than 60 Day as Year. The Used Oil Have No Regulation Thresholds.
You Generate 3 Ounces, You Are Going to Be Regulated. There Is No
Minimum Quantity. There Are Four Exceptions and That\'s to Vessels at
Sea, That\'s The Household Generators of Hazardous Waste or Household Do
It Yourselfers, It\'s for Mixtures of Used Oil Used in Machinery. And
the Fourth Exemption Is for Farmers, If They Generate on Average less
than 25 Gallons a Month, They Are Not Regulated. But Everybody Else Is.
So What Are Some of Their Management Standards? You Cannot Mixed Used
Oil with Hazardous Waste. It Has to Be Managed Separately. Second Thing
Is When Someone Goes to Pick up Your Used Oil, That Used Oil Recycler,
That Company Should Be Testing Your Used Oil to See Fit Contains More
than a Thousand Parts per Million, Pmm, of ‑‑ Ppm of Total Halogens. Fit
Does, It\'s Presumed to Be Hazardous Waste. You\'re Going to Have to
Send to It a Hazardous Waste Insin Rater. How Do You Have to Label Used
Oil? You Just Spray Paint on it like This Drum Is, Used Oil. Hazardous
Waste Regs Require You Have this Fancy Yellow Sticker And Says If this
Drum Is Found, Contact So and So to Get an Epai.d. Number. None of of Is
That Required for Used Oil and It\'s Not Waste Oil. It\'s Used Oil. You
Cannot Store Used Oil in Anything but Tanks or Containers. That Means
You Can\'t Store Used Oil in a Surface Impoundment or Any Other
Container. It Has to Be in a Closed Tank or A Container. Now, That Being
Said, When You\'re Storing it in a Tank or a Container, If You Store
Enough Petroleum, Oil and Lubricants or Pols, Petroleum Oil and
Lubricant, Your Used Oil Would Be Subject to the Spcc Regulars, And Spcc
Means Spill Prevention Control and Counter‑mesh. ‑‑ Countermeasure. If
Your Total Storage Onsite Exceeds 1320 Gallons, Then Your Used Oil
Storage must Be in Secondary Containment. Let Me Give You an Example
Every That. You Have Two 500‑gallon Tanks, One Is Diesel and One Is
Gasoline. You Have Six 55‑gallon Drums of Lubricants You Use on Heavy
Equipment. So You Are over 1,320 Gallons Right There. Your 55‑gallon
Drum of Used Oil Stored Outside Has to Be in Secondary Containment Now
Because You Have Exceeded That Threshold of 1,320 Gallons. Is There Any
Questions Related Tune? Most of the Time Our Facilities Are Not Storing
More than 1,320 Gallons. But What We Found Is There Are a Lot of
Facilities That Come When We Are to Doing an Odd and it Say I Only Have
Two 500‑gallon Tanks but They Didn\'t Count All The 55‑gallon Drums
Stored Outside. No Questions? Ok. So If You Do Wind up Building
Secondary Containment for Your Drums and Put a Drain in the Secondary
Containment, What Common Practice I\'ve Seen Is That the Valve That
Someone Puts A Valve in There and It\'s Not Closed When We\'re Doing the
Inspection. You Have to Make Sure It\'s Secure, That It\'s Chained Shut
Or Otherwise Locked. Because If Epa Was to Do an Inspection or State and
It\'s Open, You Would Be in Violation. This Is Also in Secondary
Containment, this Pyramid of Lubricating Oils. The Bottom Right Corner
Drum Has Waste Oil. It\'s Improperly Labeled but They Did re Psyche Thul
Budweiser Count to Make Sure the Oil Is Closed So We Gave a Positive
Finding for That. Again, If ‑‑ You Can Only Store In Tanks and
Containers and They Have to Be in Good Condition. So a Huge Dent in the
Side of The Drum Would Not Be Acceptable. Common Practice Is If the Dent
Is More than a Half Inch Deep or An Inch Long It\'s Not Acceptable For
Dot, So it Wouldn\'t Be Acceptable to Epa. I Will Try to Get Some User
Involvement Here. If this Is Your Used Oil ‑‑ Used Oil Storage Area and
You See All The Stained Ground in Front Where the Spills Have Occurred,
What Would You Do? Because the Regs Are Very Specific on What You Have
to Do. So Can Anybody Try to Predict What the Four Requirements Are That
Epa Has? I Encourage You to Use That Push‑to‑talk. What\'s the First
Thing You Would Have to Do If You Have this Spill?

Caller: Contain It?

K. Morin: Yeah. That\'s Actually One of the First Requirements. You Have
to Contain the Spill. So If It\'s Running down the Street, You Would
Have to Put Out Some Berm or Throw down Some Oil‑dry to Stop it from
Spreading. What Else Do You Have to Do If You Have a Spill? Anybody from
Colorado? How about East Coast? Martin Has Been Asking the West Coast.
All Right. We\'ll Go Through Them Real Quick, Then, What Epa Mandates
You Have to Do. First Thing You Have to Do Is Stop the Release. Second
Thing You Have to Do Is Contain it as the Caller Indicated. Then You
Have to Clean up and Properly Manage the Released Used Oil and the
Cleanup Materials. Now, Key Here Is the Reg Says Upon Detection You Have
to Clean Up the Spill. That Doesn\'t Mean You Have to Advertise in the
Commerce Business Daily for Three Weeks Or You Have to Wait until
Somebody Sends You Money. When That Spill Is Discovered, You Have to
Deal with it and Address It. Then Last but Not Least, the Fourth
Requirement Is Prior to Putting Any Tank or Container You Were Using
That Was Leaking Back into Service, You Have to Repair It. Now, When I
See Spills of Used Oil, a Lot of Facilities Tell Me, It\'s Leaking into
the Secondary Containment, I Can Deal Witness Later. That\'s Not
Correct. That Secondary Containment Is Meant to Contain the Entire
Volume of That Drum, and If You\'re Periodically Letting a Gallon or Two
Collect in There, You\'re Displacing ‑‑ You\'re Using up Some of the
Usable Volume. So Wheel Whole 55‑gallon Drum, If it Was to Go, Would it
Overflow. Spills of Used Oil in Secondary Containment Have to Be Cleaned
Up. You Can\'t Just Allow Them to Accumulate in There. Now, One of the
Things You Can Do If You Don\'t Want to Recycle Your Used Oil Is You Can
Burn it In a Space Heater on Site. But That\'s Subject to Three
Conditions. The First Condition Is You Only Burn Your Own Used Oil. Or
Used Oil That You Have Accepted from Do it Yourselfers. But You Can\'t
Accept it from Somebody Else. Second Condition Is That Your Space Heater
Has to Have a Maximum Capacity of Half a Million Btus per Hour. The
Third Condition Is the Exhaust Gases from Your Heater Are Vented to the
Outside. Now, When Somebody Comes to Pick Up Your Used Oil, They Have to
Have an Epa I.d. Number. Epa Gives I.d. Numbers for Hazardous Oil
Transporters and Used Oil Transporters and They Are Two Different
Classifications and When Someone Is Requesting a Number, If ‑‑ They Can
Get Both, but They Have To Notify Epa That They\'re Doing Both
Activities. So Your Hazardous Waste Contractor May or May Not Have The
Proper ‑‑ May or May Not Have Filed Proper Notification Paper Work with
Epa to Be a Used Oil Transporter. So You Need to Be Checking on That.
Whoever Is Picking up Your Used Oil, You Should Ask Them, What Is Your
Epa I.d. Number? Now, You Can Also Transport Used Oil, but There\'s
Certain Conditions Associated with it And I\'m Going to Go Through
Those. The First Condition Is That Your Transportation Has to Be in a
Vehicle That the Government Owns Or That One of Your Employees Owns. The
Second Condition Is You Can Only Transport up to 55 Gallons. And That
May Be 11 Jerry Cans or It May Be Five 10‑gallon Containers or Maybe One
55‑gallon Drum, but If You Have Two 30‑gallon Drums, You Have Exceeded
the Standard, Obviously. Then Last but Not Least, When You Are
Transporting Used Oil, You Can Either Take it to an Aggregation Point or
a Collection Center. I\'m Going to Describe the Differences. An
Aggregation Point Are Points ‑‑ Are Centralized Locations. You May Have
in Your Agency Several Fire Stations in Your Regional Office. You Have a
Couple Fire Stations, A Recreation Site and a Visitor Center. Each One
Is Generating Used Oil. They All Have Five‑gallon Buckets. When You
Occasionally Do a Milk Run and You Pick up the Five‑gallon Buckets, You
Can Bring Them Back to Your Regional Office, Which Is Your Aggregation
Point for Your Organizational Unit, for Your District Office. Or When
You Are Doing That Milk Run, You Pick it up from Those Three or Four
Locations, Provided You Are less than 55 Gallons, You Can Continue to
Drive and Deliver to it a Collection Center, but That Collection Center
Has to Be Licensed or Registered by a Local Governmental Agency. It
Can\'t Just Be Your Brother‑in‑law down the Street. It Has to Be Someone
Who Is Licensed to Accept the Used Oil, And That Means They\'re Going to
Properly Manage it and Ensure it Gets Recycled. So Here Is Another
Question for You and Hopefully We Can Get Some Response to This. You\'ve
Done Your Milk Run and You\'ve Picked up Used Oil from Several
Facilities and You Decide You\'re Going to Give the Used Oil to the
Local Automotive Body Shop Because They Have a Space Heater and They
Want to Burn It, or You\'re Going to Bring Your Used Oil, You Work For
the Forest Service and BLM Has a Space Heater and They Want To Burn It.
Can You Do That? Anybody Want to Try to Answer That Question?

Caller: No.

Caller: No!

K. Morin: Hey, That\'s the Right Answer. Give Them a T‑shirt. No, You
Can\'t. The Reason Why You Can\'t Is That Facility Is Not ‑‑ You Can
Only Deliver Your Used Oil, Remember, To A. Permitted Collection Center.
So They Might Be ‑‑ Let\'s Say The Local Gas Station Is a Permitted Used
Oil Collection Center. But They Can\'t Burn That Used Oil Because They
Didn\'t Generate It. If They Do Want to Burn It, They Have to Have a
Permit to Burn Used Oil That You Get under Subpart G and a Permit to
Burn Someone Else\'s Used Oil Is Equivalent to Getting a Hazardous Waste
Incinerator Permit and That Local Gas Station Isn\'t Going to Have It.
So That Used Oil F You Want to Burn It, That\'s Fine, but You Can\'t
Give it to Anybody Else to Burn. It Has to Be Recycled If You\'re Not
Going to Burn it in a Space Heater. So What I Want to Go Through Now Are
Examples of Proper Used Oil Storage. This Secondary Containment Shelter
Works Great. Someone Can Come in Easy a Five‑gallon Bucket. They Could
Also Dump Solvent in And It. So If You Are Concerned about All Vent
Going In, You Can Buy These Bung Locks That Goes over The Vent Bung and
the Two‑and‑a‑half Inch Bung and You Have to Have a Key to Get in to
Dump the Used Oil into It. Here\'s Another Type of Secondary Containment
You Can Use. But I Don\'t Recommend this Pick Style of Secondary
Containment. The Reason Why Is You\'re Always Going to Have Some Sort of
Funnel to Be Able to Pour the Used Oil into the Drum. Here Is a Drum
Funnel This, Black Thing on Top If That You Are in a Rainy Environment
and You Don\'t Want Your Secondary Containment Filling with Rain Water,
You Can\'t Close Witness The Drum Funnel. And in Between Uses the Drum
Funnel Gets Dumped Behind the Container. There Is Residual Oil in That
Funnel and Here Is a Close‑up of It. You Can Say the Stained Soil Here.
Remember What I Said, upon Detection of a Release of Used Oil, You Have
to Clean it Up. That Doesn\'t Mean You Have to Send it Immediately to a
Dirt Burner. You Could Pick up the Soil, Put It on Some Visqueen and Do
Some ‑‑ Institute Buyer Remediation but You Have to Deal With the Spill.
You Can\'t Just Let it Stay There. Now, this Is the General Style Of
Secondary Containment Shelter I Recommend, but it Comes in Two Models.
This One You Can See the Doors Are Too Shallow on it as Well. This One
Has What I Call High Bay Doors. You Can See That the Funnels Can Be Left
on this Drum So It\'s Very Easy for Someone to Be Able To Pour the Used
Oil into It. It\'s Also to Keep it Closed to Make Sure There\'s Not Rain
Getting in There. Now, Another Question for the Audience, How Do You
Have to Manage Used Oil Filters So That You Are Exempt from Hazardous
Waste Regulations? Can I Just Set Them ‑‑

Caller: You Have to Punch a Hole in the Top of Them.

K. Morin: Excellent. You must Have Had a Cashe Audit. They Have to Be
Gravity Hut Drained and Punctured on the Dome End. There Is Actually an
Exemption That Says If You Do That, Provided It\'s Not a Turn‑plated
Filter, and Those Aren\'t Being Made Anymore, So I Doubt You Have Them,
but Once You Have Gravity Hut Drained it and Punctured It, it Can Go
Right in The Trash. Now, Old Habits Die‑hard and I Have Seen a Lot of
Secondary Containment Shelters, Because We Are Doing Our Second Round of
Audits Now, and I Have Seen an Awful Lot of Secondary Containment
Shelters out in the Field for Storage of Used Oil But What Happens Is
We\'re Still Accumulating Used Oil in Five Gallon Buckets. So When You
Are Walking Around Your Facility, You Should Be Looking for That. Just
Because We Set up the Right Practice, Doesn\'t Mean All Our Employees
Have Implemented It. So I Am Asking You Managers and Haz‑mat
Coordinators to Be Vigilant and When You Are Seeing These Practices
Where It\'s Not Going in the Right Container, You Should Be Talking to
Your Staff and Reminding Them to Properly Use the Accumulation or
Aggregation Point That You\'ve Generated. With That I\'ll Turn it over
to You, Frank.

F. Mills: Now We Would like To Go into Another Area That\'s Material
That We Are Heavily Regulated In, and That\'s the Area of Lead. Now,
Many of You Have Seen Our Activities Involving Lead‑based Paint and
We\'re Very ‑‑ as Agencies We\'re Getting Ready to Get Rid of Most of
Our Lead‑based Paint Activities Through or Normal Pollution Prevention
Programming, but There Is an Area That\'s Kind of Hidden on the Horizon
That Is Going to Be Coming More and More Important to You as a Land
Management Agency Manager, and That Is the Area of Firing Ranges. Firing
Ranges and Lead Are One In the Same. Almost All of the Regulations That
We\'re Going to Start Seeing About Firing Ranges Are Going to Pertain to
the Metal Lead, and How it Is Affected in the Environment. Many of Our
Firing Ranges, You Know That the Lead Is Impacted And When Lead Is Left
out in the Open, it Oxidizes in Air. It Also When It\'s ‑‑ Attaches to A
‑‑ Acidic Water or Soils, the Lead Dissolves and Gets into Our Water
Tables. This Dissolved Lead Is Moved Into the Environment Through Storm
Water Runoff, Through Leaching, Through a Number of Areas That We Have
to Deal With, And We Need to Be Really up on What\'s Going to Happen in
the Future. I Would like to Talk to You Now About a Couple of Things
about Firing Ranges. First, the Courts Have Said That Lead and Lead Shot
at Firing Ranges Are a Hazardous Waste. So That Means That When We Start
Talking about Dealing with Them And Handling Them, We\'re Going To Have
to Deal with Them and Handle Them under the RCRA Statute. Second, Many
Times Activities That We Have Are Dictated by Other Agencies, and One of
Those That Deal with Ranges Quite Extensively Is the Department of
Defense. Epa Has Told the Department of Defense That They May Have to
Make EPCRA Reporting on Lead Usage at Firing Ranges. This Is an Issue
That Our Solicitors and Our Ogc Offices Are Going to Have to Look into
And Decide Whether or Not We as Agencies Who Manage Firing and Shooting
Ranges Might Come under This EPCRA Reporting. That\'s Something That\'s
in the Future That You Need to Be Aware Of. Another Area That\'s
Important About Firing Ranges Is the Clean Water Act. Now, the Courts
Have Said That Firing Ranges Are Point Source Discharges of Pollutants
into The Environment. Now, That Means the Entire Firing Range Itself
Discharges Pollutants into the Environment. And the Courts Have Said
under The Clean Water Act That Bullets And Lead Shot Are Pollutants. So
That Means That We Have to Be Very Careful Any Time Our Firing Ranges
Are near or over Water Bodies. If We\'re near a Lake When We\'re
Shooting, We Need to Consider The Topography of the Land and Whether or
Not the Storm Water Runoff Will Drain into a Lake or Stream Nearby. If
We\'re Shooting out over Areas Of Open Water, for Instance, Skeet
Shooting, We Need to Be Very, Very Concerned That We Are Violating Clean
Water Act Regulations at That Point. Now, What Can You Do as a Manager
to Control the Environmental Situation at a Firing Range? Well, the
First Thing You Can Do Is Have an Active Program to Manage the Lead at
the Firing Range. We Can\'t Just Have a Firing Range and Pretend it
Doesn\'t Exist. If We Do That, Then We\'re Subjecting Ourselves to a Lot
of Open Citizen Suits, and These Suits Can Force Us to Take Actions That
Are Very Expensive. So What We Want to Do Is Develop A Proven, Tested
Program to Manage the Lead on Our Ranges. We must Remember If That
You\'re Going to Recycle the Lead, What You Would Have to Do under RCRA,
It Has to Be Done Any Range. You Can\'t Have the Lead Picked Up and
Moved off of the Range. It Has to Be Done There. And the Soil That the
Lead Comes Out of Has to Be Left at the Range. Now, under the Clean
Water Act, If You\'re near a Water Body, You Need to Go and Obtain a
National Pollution Discharge Elimination Permit. This Is to Ensure That
Any Discharge That We Have Meets the Permitted Requirements and We Are
Not Subject Again to Citizen Suits. Oftentimes Our Ranges Are Both Used
by Public and Our Own Personnel Such as Law Enforcement. It Does Not
Matter Who Uses the Range. It\'s the Management of the Range That\'s
Important. And Lastly, If You Decide as a Manager to Close a Range and
to Remove it off of Your Facility, Remember, That Closure must Be
Completed under the CERCLA Regulations and That You Have to Follow an
Extensive Program of Planning, Environmental Impact And Other Areas to
Design a CERCLA Removal for That Range. Now, What I Would like to Talk
To You about a Special Pamphlet And Things That Epa Has, but There\'s
Some Other Issues That We Need to Address Before We Get Into How Epa
Would like You to Handle a Range Issue. First Is Vandalism at Our
Ranges. Vandalism Causes What We Consider an Attractive Nuisance And One
of the Areas That\'s Particularly Important to You as A Manager Is the
Area of Children and Attractive Nuisances. As We Allow People to
Vandalize Our Ranges, it Appears That the Ranges Can Be Used to ‑‑ for
Other Things, Beer Parties Is an Example, Anything That We Allow To Go
on There. Children Who Come in Contact With Lead Suffer Probably the
Greatest Impact from That That We Can Have, and Most of Your Federal
Programs Impact Children When You Talk about Lead. Bullets on the
Ranges, Children Can Pick Them Up. Many Times in this Photograph You See
Actual Rounds Laying in The Ground. Children Have a Tendency to Eat Dirt
and Put Things in Their Mouths That They Pick up from Things like That,
and this Is Another Attractive Nuisance Issue That We Need to Be
Prepared to Handle. For Instance, Raking Our Ranges And Ensuring That
Trash and Things Aren\'t There. Another Area That\'s Very Important Is
Leftover Brass. A Lot of this Brass Has to Be Handled as RCRA Hazardous
Waste Because There Oftentimes Are Unexpended Powders Inside the Brass
or Even Ammunition That Has Become a Dud and Failed to Fire and Has Been
Discarded by The Shooter. If These Materials Are Sent to a Hazardous
Waste Facility Without Properly Classifying Them as Reactive Waste, We
Can Be Held Liable for Damages to Both the Facility and Personnel While
They\'re Treating the Waste at The Facility. Now, Epa Has Taken a Very
Strong Effort and Has Gone to Great Detail to Provide Land Management
Agencies with a Pamphlet That Explains the Things That We Need to Do as
Land Managers to Manage Our Outdoor Shooting Ranges. And on the Screen
You\'ll See the Pamphlet Number Which Is\.... Epa‑902‑b‑01‑o Ohio Von.
This Can Be Obtained from the Epa Website If You Put in \"Best
Management Practices for Lead at Outdoor Shooting Ranges.\" It Is
Incumbent upon Us as Managers and Agency Supervisors To Ensure That this
Is One Area That We Are Watching Over. Martin, If We Have Any Questions
From the Audience or If You Have Anything Else. You Would like to Bring
up about Lead at Shooting Ranges.

M. Thrasher: No, That\'s All I\'ve Got for Right Now. I Sure Would like
to Encourage Anybody to Call in or Use Your Push‑to‑talk. We\'ve Got
about Four Other Special Wastes or Hazardous Materials Issues That We
Need to Present to You, but at Any Time During the Program, Interrupt
Us. We Would Be Glad to Go Back and Cover Those. Let Me Go Ahead and
Cover Three More of Them Rather Quickly Here. The First One That I\'d
like to Mention to You Is Asbestos‑containing Material or Asbestos
Waste. Asbestos Happens to Be One of The Most Highly Regulated Materials
That We\'ve Got. And Without Going Through the Thousands of Regulations
and Rules about That, I Thought I Would Mention Three of the Primary
Things That I Think Managers Ought to Be Aware Of. First of All, If
You\'ve Got a ‑‑ An Asbestos Containing Material That\'s Called Friable
and Friable Means That You Can Take It in Your Hand and Crush it and
Release the Finers by Hand Pressure, Then That Means That You\'re Going
to Need to Abate That Material. Now, Unfortunately, for Many Years the
Term Abatement Has Been Used Synonymously with Removal. So a Lot of
Managers Have Presumed, Well, They\'ve Got to Remove Asbestos Containing
Materials from Facilities. That\'s Not Correct at All. The Term
Abatement Primarily Means Three Things\... One Is You Have an Option to
Encapsulate That Particular Material So the Finers Can\'t Get Away and I
Will Show You Some Pictures of That Here in a Moment. The Second
Management Option Is To Build an Encloseier ‑‑ Around The Asbestos
Containing Material. The Third Option, of Course, in Removal of the
Asbestos Containing Material. So When People Talk about Abatement, Those
Are the Real Three Management Options That You Need to Be Discussing
with Your People. Now, the Second Area That I Think the Managers Ought
to Be Aware of Is When They\'re Doing a Renovation in a Building, in
Other Words, Moving Walls, Replacing a Ceiling, Putting in Attachments
to Walls or If Hear\' ‑‑ They\'re Doing a Demolition of Building,
Tearing A Building Down, in Most Cases, A Renovation or Demolition of a
Building Requires You to Do an Asbestos Survey Prior to Commencing Work,
and If You Have Asbestos Containing Materials That Are Going to Be
Disturbed, Then You\'re Going to Have to Get A Permit in Order to Do the
Renovation or Demolition, and Then Follow Numerous Rules in Getting Rid
of the Stuff Before You Get onto the Main Part of The Work. The Last
Thing That I Want to Mention with Regard to Management of Asbestos
Relates To Disposal of Asbestos Containing Material, in Other Words, the
Waste. Asbestos Is a Hazardous Substance under CERCLA. So Whenever You
Dispose of That Stuff in a Landfill, Certainly It Has to Go to a
Permitted Facility and Then You Need to Know That If That Facility Ever
Has to Be Cleaned Up, You May Be A Potentially Responsible Party Under
CERCLA for the Cleanup. So You Need to Think about That In Terms of
Where Am I Going to Send My Asbestos Containing Waste, Because the Most
Places You Send It, the More Liability That You\'ve Got. Typically I
Recommend That People Go to the Same Place for Disposal of Asbestos
Containing Material and Not Use a Whole Bunch of Different Places
Around. Let Me Show You Some Visuals of Some Asbestos Containing Suspect
Asbestos Containing Material You Might Be Aware Of. Here\'s Some Blown
Insulation and Sometimes, Particularly in Older Buildings, Typically
Prior to 1980, this Material Might Contain Asbestos Finers. Here\'s
Another Depiction of Some Pipe Wrap, and Typically When I See Something
like This, When I See a Wrapping like This, I Think That That\'s
Probably Fiber Glass Wrapping, but You Don\'t Want to Lose Site of the
Ends. Typically at the Ends, Oftentimes at the Corners of These, Even
Though They Have Fiber Glass Here in the Middle, They\'ll Leave the
Asbestos Insulation on the Corners and at The Valve Areas. So You Need
to Be Careful of That. Now, Here Is Another Depiction That You Really
Need to Be Concerned about and Take Care of Right Away, and That\'s When
You Get this Type of Pipe Wrap Material That\'s Actually Dropped Down
from the Pipes and Is on The Ground. That\'s a Friable Material and it
Must Be Cleaned up in Accordance With Asbestos Regulations. This next
Photo Is a Rather Obscure, but it Kind of Stretches Your Thinking, a Lot
Of These Old Boilers Will Have Asbestos Pipe Insulation Around The
Pipes, like this One Here That\'s on the Exterior Here. Here\'s Another
One up Here. In this Case You Can See There Is No Insulation on the
Exterior Of These Pipes and You Might Think We Have No Asbestos Issue.
But What You Need to Do Is Have Your Folks Open up the Doors. Because
Oftentimes Inside These Doors or on the Floor of These Boilers You\'ll
Find a Tile That Contains an Asbestos Type Products. Now, Lastly I Wand
to Show You a Kind of Benign‑looking Older Building, and You Might Not
Think of Asbestos Here, but Oftentimes the Roofing Tile Might Contain
Asbestos. There Might Be Asbestos Insulation Blown in under the Roof or
in the Walls. But the Other Thing That I Want To Bring to Your Attention
Is The Siding Here. Let\'s Take a Look Close‑up of That. As You Can See
on That Particular Building, Somebody Had Done a Test And, in Fact,
Determined That the Siding Contains Asbestos Finers and So If You Ever
Do a Renovation or Demolition of That Building, You Would Have to Make
Sure to Follow All the Asbestos Rules in Doing That. If You Have Any
Questions about Asbestos, It\'s a Subject That\'s Highly Regulated at
the State Level. So You Certainly Need to Check With Your State
Regulators. The next Topic Is ‑‑ Relates to Radon. Radon Is a Naturally
Occurring Gasp Results from the Decay of Uranium. There Are No Mandatory
Limits For Radon Except the Epa Has Recommended Levels in Residential
Structures and for Federal Facilities That Are Occupied You Need to Do a
Survey For Radon Gas. The Guidance, the Epa Guidance Here, Is Four Pico
Curries per Liter. You Do That by Doing a Test and Sending in the
Testing Capsule. If You Exceed the 4, Then You Need to Implement Some
Type of Abatement Technique, Which Is Usually Some Type of Engineering
Controls to Either Vent the Radon Gasaway from the Structure Or to Vent
the Inside of the Structure to Introduce More Clean Air. The next
Subject I Want to Mention Very Briefly Is Mercury. Mercury Is Commonly
Found in Thermometers, Thermostats, Fluorescent Light Tubes and Metering
Devices Such as Water Meeters and Gas Meters. Here Is a Depiction Here
of a Thermostat, and You Can See There Are Four Mercury‑containing Vials
Here. If You Are Ever Dealing with Mercury, There Are Two Management
Things You Need to Be Aware Of. One, If You Have a Release of The
Mercury, There Are Very Stringent Requirements in Terms Of Employee
Training and Methods For Cleaning That Up. So Yo Want to Make Sure to
Have That in Place, or Better Yet, Get Rid of the Mercury So You Don\'t
Have to Worry about a Cleanup. The Second Thing That Managers Ought to
Know about Is ‑‑ Relates to the Disposal of Mercury. If You Dispose of
Mercury into a Landfill, it Has to Go to a Hazardous Waste Facility That
Accepts Liquid Mercury, and It\'s Simply Not a Good Option to Handle it
That Way. The Best Management Practice Is To Recycle Mercury. There Are
Quite a Few Mercury Recycling Companies in the United States. They Will
Pick up Shipments of Mercury like in the Thermostat Or in Your
Fluorescent Tubes, And They Often Actually Pay You For the Mercury That
They\'ve Recovered. So It\'s a Real Good Management Option to Just
Recycle the Mercury. It\'s Easy to Do. Make Sure to Call in with
Questions about Any of These Things I Covered and What I Wanted to While
We\'re Waiting For the Questions Is Just Turn It over to ‑‑ Sit Frank,
Are You Going to Cover the Explosives?

F. Mills: Yes, I\'ll Cover a Peer Shun of the Explosives Today. What We
Would like to Talk to You Now about Is Another Area Known as Uxo or
Unexploded Ordnance and I Am Going to Cover Three Specific Situations,
and Ken Is Going to Cover a Fourth. What I Really Want You to Understand
Is That No Matter What Kind of Explosive You Deal With, and How It\'s
Handled, it Is an Environmental Event under The Law. It Is Covered by
RCRA as a Statute. And Even Though We Have Some Pretty Unique
Situations, for Instance, Bombs, You May Have a Person Put a Bomb at One
of Your Visitor Centers and You Call in A Police Bomb Squad, or You May
Have a Military Ordinance Discovered from an Old Military Range or
Dropped off by a Visitor to a Park. Or You May Have a Situation Where
You Have a Drug Lab Which Has Explosive Materials. In All of These
Cases, You\'re Going to Be Calling an Outside Agency in Coordination
with Your Law Enforcement Personnel to Work with You on These Issues. I
Want You to Note That You as The Manager under the Law Working Within
Your Scope of Your Responsibilities and under Your Official Capacity
Have Some Legal Requirements under RCRA That You Have to Be Aware of and
That\'s Very Important That You Read Those Responsibilities in The RCRA
Regulations. But I\'d like to Cover Quickly One Thing. If a Bomb Squad
Comes to Your Facility and They Take a Device And They Take and it Blow
it Up, That Device Is Blown up under a RCRA Statute and That Means That
They Have Protection under the Law That They, the Bomb Squads, Are Not
Responsible for What Happens to the Environment, but You as the Land
Management Agency Manager Are Responsible. After They Leave, You May Be
Left with a Cleanup under CERCLA To Take Care of the Residual That\'s
Left after the Explosion. That\'s Important to Note. The Bomb Squads
Have to Record The Location and in Many Cases They Have to Obtain a
Permitted To this Work. They Don\'t Just Have the Ability To Do it
Without Checking with The Environmental Organizations. Through this
Permit, the Location and the Action Is Recorded, and Months Later You
May Receive in the Mail a Notice From Epa That You Now Have a CERCLA
Site That Now Needs Cleaning Up. So Please Remember, Even in the Direst
Emergency, There Are Responsibilities That You Have As a Manager Dealing
with Unexploded Ordnance and the Environmental Laws. Ken, Will You Cover
the Other Situations Now?

K. Morin: Thanks, Frank. I Want to Quickly Go over Abandoned Mine Lands
and What You Should Be Doing. Every Land Management Agency in The
Country Has an Aml Program Of Some Type and We Have People Going out in
the Field Walking Up to Mine Addits and Seeing What Has Been Left
Behind. Sometimes It\'s Just Used Oil or Cyanide. Sometimes It\'s
Dynamite as Pictured Here in the Container Down Here. Now, Everyone I
Think Knows How To Properly Handle the Used Oil And the Cyanide,
Disposing of Those as Hazardous Waste or Recycling Used Oil. But Is
Dynamite Hazardous Waste? I Think as Frank Told You, it Is Definitely
Regulated under RCRA And the Definition for a Reactive Hazardous Waste
Right Here Says a Solid Waste That Exhibits These Characteristics. It
Will Explode under Standard Pressure or It\'s Forbidden He Can Closive
as Defined by D.o.t. And Dynamite Meets Both of These Categories. So it
Definitely Meets the Definition of Reactivity. So If We Want to Blow it
Up, Is It Considered Hazardous Waste Treatment or Disposal? It
Definitely Is. The Definition Is Any Method Designed to Render Something
Nonhazardous or Make it Safer to Transport. And Blowing up Dynamite Does
Both of Those. Disposal. , it Also Meets the Definition Of Disposal
Because it Means We May Result in the Release of Pollutants into the Air
or the Ground Water and When You Have An Explosion, You Obviously
Release a Variety of Pollutants Into the Air. Society Question Is Do You
Have Have to Have a ‑‑ So the Question Is Do You Have to Have A Permit
to Treat Abandoned Dynamite? And the Answer Is Definitely Yes Because
Treatment of Hazardous Waste Is Regulated under 40cfr 264 but There Are
Some Kinds of Treatment That Are Exempt and I Am Going to Go over That
Exemption. It\'s Actually the Same Exemption That Frank Was Just Talking
About. Under the Regulations, a Treatment of He Can Closive Hazardous
Waste Is Exempt Provided You Meet These Two Conditions, You Have an
Explosive or a Munitions Emergency Response Specialist, And Note I Put
in That Quotes, Because That\'s How It\'s Referred To as the Regs ‑‑ in
the Regs. If this Specialist Determines an Immediate Response Is
Necessary, Then You Can Blow it in Place Without Having to Go Through
and Get a Full‑blown RCRA Permit. You\'re Still Subject to RCRA
Notification Requirements, but We Don\'t Have to Get a Full‑blown
Treatment Permit. And the Key Phrase There Is Immediate Response.
Because If You Go to Blow Dynamite and ‑‑ Let\'s Say You Identify it and
You Say, Ok, I\'m Going to Come Back in Three or Four Weeks, Going to
Hire a Certified Blaster to Come out Here and Do That, That\'s Not an
Immediate Response. You Have to Go Through the Permitting Process and
When this Happened in Colorado, I Was Talking to Our Local Environmental
Coordinator, I Said, Talk to the Regulator Because the Individual
Didn\'t Believe Me at First. Sure Enough, the Regulator Said, Yes, We
Have Emergency Treatment Permits That We Issue. They\'re Relatively Easy
to Get. You Have to Post Something in The Newspaper Explaining What
You\'re Going to Do, but It\'s a Very, Very Quick Process, Much, Much
More Refined, Much Easier Than Trying to Get a Permit for Like a
Hazardous Waste Incinerator Which Take Years. They Can Issue this Permit
in as Quick as Seven to Ten Days. That Wraps it up for Explosives At Aml
Sites.

M. Thrasher: We\'ve Covered Some Special Wastes, Special Hazardous
Materials Rather Quickly. So I Want to Invite You to Ask Any Questions
You Have about These or Perhaps Any Others That Are of Concern to You.
So Use Your Push‑to‑talk and Go Ahead and Get Online with Us Here and We
Would Be Glad to Do That. If You Don\'t ‑‑ Can\'t Think of Anything
Immediately, Make Sure To Stay with Us on That. We Would Be Glad to Go
Back to It Toward the End of the Program If You Have Any Questions. What
I Would like to Do Now Is Turn to ‑‑ I Think What\'s Become My Favorite
Part of this Program, and That\'s \"The Hazmat Challenge,\" Tony.

T. Garrett: All Right. Thank You, Martin. Yes, Indeed, It\'s Time Now to
Test Your Knowledge and Understanding of What We\'ve Covered Today. We
Have a Game Show, \"The Hazmat Challenge.\" You Know the Rules. Using
the Board You See on Your Screen, Our Contestants Will Take Turns
Selecting Squares and Answering the Questions Behind Those Squares.
Answer Correctly and Claim the Square. The Team to Claim the ‑‑ Three
Squares Horizontally, Vertically Or Diagonally Will Be the Winner. And
We\'ll Have Martin Be the Final Judge. And in Today\'s Game, Everyone
Who Calls in Will Receive this Special Prize. This Is the Official
\"Hazmat Challenge\" T‑shirt. So All of You Who Check in ‑‑ All of You
Who Participate in The Game Today Will Receive One Of These. Get Ready
to Push to Talk or Call in on the Telephone at this Number\.... Anyone
East of the Continental Divide Will Be on Team East. All of You West of
the Continental Divide Will Be on Team West. If You Are Ready to Play,
Let\'s Go Ahead with the \"Hazmat Challenge.\" Anyone from Team East,
East of The Continental Divide, Feel Free to Push to Talk and Check In
with Us Right Now. . We\'re Waiting ‑‑

Caller: this Is Chris from Pictured Rocks. I Will Go for It.

T. Garrett: Thanks Very Much For Checking in with Team East. Go Ahead
and Select a Square.

Caller: Let\'s Go with 5.

T. Garrett: the Question, Chris, Is Abandoned Mine Lands, Aml,
Explosives Are Considered A. Toxic Chemicals B. Hazardous Waste C. Used
Chemical Waste. Chris, You Have 10 Seconds.

Caller: How about B?

T. Garrett: Let\'s Check. Indeed it Is Hazardous Waste. Nice Going,
Chris. Team East Puts an X Right in the Center of the Box. Let\'s Go to
Team West. Anyone West of the Continental Divide, Check in with Us Now.
We\'ve Had a Couple Calls from Oregon Earlier. Go Ahead. Go Ahead and
Push to Talk. Anyoneest ‑‑

Caller: this Is Mark from Yellowstone.

T. Garrett: Go Ahead and Select a Square.

Caller: it Wasn\'t Mark, but It Is Now. Number 1.

T. Garrett: Number 1, Which Of the Following Is Not Required By EPCRA?
Is it Submission of Material Safety Data Sheets? Transportation of
Substances, Including Storage? Or Handling Public Information Requests?
Which of Those Is Not Required By EPCRA? Mark, You Have 10 Seconds Now.

Caller: B., Boy.

T. Garrett: Mark Says the Answer Is B. Let\'s Check. That Is Correct.
Team West Puts an O in Square Number 1. Let\'s Go Back East. Anyone from
the East of the Continental Divide?

Caller: this Is Pat.

Caller: this Is Kate from Virginia.

T. Garrett: Kate, I\'m Going To Ask You to Hold On. Let\'s Ask Pat I
Think from South Carolina. Go Ahead and Select a Square.

Caller: Number 9.

T. Garrett: Number 9 the Question Is, Pat, How Many Extremely Hazardous
Substances Are Listed in Friday Cfr Part 355, Approximately? Sit over
360? It over 540, over 860?

Caller: I Believe It\'s A. Let\'s Check ‑‑

T. Garrett: Pat Is Correct. Over 360. Pat Representing Team East Puts A
Square on Number 9. Let\'s Go Back West. Anyone West of the Continental
Divide Check in with Us.

Caller: Pauley ‑‑ Polly, Petrified Forest.

T. Garrett: Which Square Would You like for Team West?

Caller: Number 2.

T. Garrett: the Question Is True or False: More than 10,000 Pounds of
Cement Onsite with an Msds Attached Is Reportable under Section 313 of
EPCRA? You Ever 15 Seconds.

Caller: True.

T. Garrett: She Says True. And the Answer Is True. Posting an O on
Square Number 3. And Team West Is Threatening There Across the Top of
the Board. Let\'s Go Back East. Kate, Are You Still with Us?

Caller: Yes.

T. Garrett: All Right, Kate, Where Are You Calling From?

Caller: Prince William Forest Park in Virginia.

T. Garrett: Good. Go Ahead and Select a Square, Kate.

Caller: I\'ll Select Number 8, Please.

T. Garrett: Kate, Number 8, The Question Is Tpq Stands for A. Total
Product Quality B. Threshold Planning Quantity C. Total Pollution
Quotient. Kate, You Have 15 Seconds.

Caller: That Would Be B., Threshold Planning Quantity.

T. Garrett: Ok, You Are Correct. And for Team East, You\'ve Put an X.
Let\'s Go Back West Now and Ask Any Office, Any Viewer from West Of the
Continental Divide Check In with Us and See If West Can Wrap it Up.

Caller: Pat from Pet Raw Filed Forest.

T. Garrett: Go Ahead, Petrified Forest. Let\'s See Which Square You
Would Like to Select.

Caller: Number 2.

T. Garrett: Nice Choice. Which of the Following Is Not Required by
EPCRA, Not Required By EPCRA? Is it Facility Emergency Coordinator?
Emergency Conference Facilitator? Or Emergency Release Notification? You
Have 15 Seconds.

Caller: B.

T. Garrett: and the Answer Given Is B. Oh, No ‑‑ Let\'s See, Emergency
‑‑ Yeah, That\'s Correct. That Is the Correct Answer. Congratulations
Team West! All Right. Well, Thanks. Congratulations to Team West.
Everybody ‑‑ Everyone Who Called In and Helped Team West Take Another
Round of \"HazMat Challenge,\" and Once Again, All Of You Who Called in
for Either Team West or Team East Will Be Receiving the Official
\"HazMat Challenge\" T‑shirt. To Claim Your Prize, You\'ll Need To Send
Me an E‑mail with Your Mailing Address. So Here Is My E‑mail Address.
Now We\'ve Reserved Some Time For Your Questions and Comments About Any
of the Material That We\'ve Covered in Today\'s Broadcast. So the
Captain Has Eliminated The Green Light and You\'re Free To Push to Talk.
Call Us on the Telephone or Send Us a Fax with Any Questions. I Think
That Was a Pretty Exciting Round of \"HazMat Challenge,\" Martin. I Hope
That Met Your Expectations.

M. Thrasher: Tony, I Think It\'s the Best. I\'m Convinced it Has Some
Real Commercial Possibilities.

T. Garrett: I Am Looking into Franchising and That Let You Know How it
Goes.

K. Morin: You Could Be Taking Regis\' Job Soon.

T. Garrett: Any Questions From Any81 That Our ‑‑ Anyone in Our Viewing
Audience on the Material Covered? There Were Any Questions Incorrectly
Answered?

M. Thrasher: They Were All Correct.

T. Garrett: I Think They Were Aced. So Our Instructors Have Done a Good
Job Today and Obviously the Audience Has Done a Good Job in Assimilating
That Material.

Caller: I Have a Question About the Threshold Quantities We Talked about
Earlier in the Program.

T. Garrett: All Right. And Who Is Calling?

Caller: this Is Chris. One of the Losers from Pictured Rocks Here.

T. Garrett: Chris, There Are No Losers in \"HazMat Challenge.\"

Caller: for the Cca Pressure Treated Lumber, When We Talked About the
10,000 Pound Threshold, Is That the Total Weight of the Cca Material and
The Lumber Material or Sit Just The Weight of the Cca Treated Material
That Would Be in It?

K. Morin: It\'s the Total Weight of the Lumber Itself. Because What
Happens ‑‑ What Happens Has the Msds. The Msds Is for the Lumber Itself.
You\'re Reporting the Product. You\'re Not Reporting the Chemical When
You\'re Doing the Msds Inventory Submission, Unlike Some of the Other
Notifications Where You\'re Reporting on How Many Pounds of Benzene You
Have, When You\'re Doing the Msds Inventory, You\'re Reporting on the
Product Itself.

Caller: Very Good. Thank You, Ken.

K. Morin: You\'re Welcome. Any Other Questions?

T. Garrett: We Want to Thank Chris for Checking in with Us. Anyone Else
in Our Viewing Audience Have a Question about The Material That We\'ve
Covered Today? I Do Want to Clarify Something. I Think Our Participants
from \"HazMat Challenge\" in the First Round and in the Second Round
Also Should Be Eligible for the T‑shirt.

F. Mills: I Do, Too.

T. Garrett: So If You\'ll Send Me an E‑mail with Your Mailing Address,
If You Did Participate, We Will Make Sure You Get One of The Official
\"HazMat Challenge\" T‑shirts. Any Other Questions from Our Audience
Today?

Caller: I Have a Question On ‑‑

T. Garrett: Steve in Worland, Go Ahead.

Caller: It\'s Been My Understanding Prior to Today That as Long as
Munitions Were Discharged They Are Not a Hazardous Waste Because That
Was The Intended Use of the Discharge of That Munition. Is That Correct
or Not Correct?

F. Mills: That Is Correct. The Epa and the Courts Have Said That the
Discharging of the Weapon. And the Firing of the Bullet Itself Is Not a
RCRA Action. But They Have Also Said That Once the Bullet Enters the
Environment and Is ‑‑ Remains There over a Period of Time, Then it
Becomes a RCRA Issue. So the Firing Range Itself and The Act of Shooting
the Gun Is Not Regulated under RCRA for That Act, but Once the Bullet
Strikes the Environment and Becomes a Part of the Environment, Then the
RCRA Statute Takes Place and Becomes An Issue Here. So It\'s Kind of a
Nebulous Kind Of an Answer, I Know, but They Have Actually Put it on
Both Sides of the Issue, That the Actual Gun Itself and Firing the
Bullet Is Not RCRA but Once the Bullet Strikes the Environment It
Becomes RCRA Issue. Does That Help?

K. Morin: If I Can Add Something. It Becomes a RCRA Issue When You\'re
Going to Do Something to That Berm. I\'ve Done a Lot of Work with Firing
Ranges with the Military And There Was So Much Lead in it There Was
Ricochet Coming out it At the Marine Corps Base at Quantico. When You
Are Rebuilding That Berm That\'s When RCRA Kicks In. When It\'s an
Active Shooting Range and the Public Is Enjoying And it Everybody Is
Using It, It\'s a Shooting Range. But When the Facility Goes to Get ‑‑
When the Berm Gets to Be Rebuilt, That Dirt You\'re Removing Is Going to
Be a RCRA Action. If the Facility Is Abandoned and No Longer Used, Then
the ‑‑ Then It\'s No Longer in Operation, It\'s No Long Ear Facility,
You Have Essentially Abandoned the Lead in the Environment, RCRA Kicks
In.

F. Mills: Right. And the More Important Statute To Deal with in Firing
Ranges Is Not RCRA, but It\'s the Clean Water Act. Most of the ‑‑ Most
of the Times At Firing Ranges Have Been Subject to RCRA Action, It\'s
Because They Have Actually Impacted the Waters of the United States, and
the Broad Definition Through the Courts Is That the Firing Range Is in
That Case, When You\'re Dealing with The Clean Water Act a Point Source
Discharge. So If You Fail to Follow the Nepde Permitting Requirements or
The Lead Starts Leaching Offsite, Then You\'re Bound to Clean it up to
Protect the Water. When Start Cleaning it up to Protect the Water, Then
You Have To Clean it it up under RCRA Conditions and CERCLA Conditions
Also. So What RCRA Does Is it Allows You to Recycle, Reclaim the Lead
Without Attaching Many Other Issues to It, as Long as That Reclamation
Is Done at the Firing Range Itself, Not Off‑site. So in That Case, RCRA
Helps.

T. Garrett: Steve, Thank You For Checking in with Us from Worland. We
Have Time for One More Question If There Is Another Question from Anyone
in the Audience. If Not, Then, We\'ll Turn it Back To Martin.

M. Thrasher: All Right. I Think That Firing Range Issue Points out One
of the Real Problems and Challenges in this Business, Is That People Ask
a Very Specific Question, They Get A Very Specific Answer, Which Is
Correct, and Yet There Are Lots Of Other Regulations and Laws Which
Weren\'t Asked About, Weren\'t a Part of the Answer, And So We Sometimes
Make the Mistake of Making the Presumption That the Answer to That
Question, Then, Is the Answer to the Entire Question And That Isn\'t the
Case. So It\'s Pretty Complicated and It\'s Difficult for Managers. But
We\'re Trying to Help You out In this Course. What I\'d like to Do Now
Is Turn To the Last Knowledge Assessment To Kind of Challenge Some of
Your Thinking and Skills Here And We\'re Going to Do this the Same Way
That We Did the Last Knowledge Assessment When We Got Into the Talking
about Special Wastes. What We\'re Going to Do Is Show You this Depiction
of a Storage Yard, a Wareyard of Sorts and The Challenge Here Is to
Thing About and Right down Different Hazardous Materials Issues That You
See in this Site. Again, Don\'t Worry about Whether Or Not Your ‑‑
You\'re Correct. What We\'re Looking for Here Is Issue Identification.
Late or We Can Figure out or You Are Experts Can Figure out Whether
It\'s a Viable Issue. So Take a Minute or Two Here to Look at this Scene
and See What Kinds of Issues Come to Mind. Jot Them Down. We\'ll Talk
about Them near a Minute. . Welcome Back. What I Would like to Do Is
Call On Anyone That\'s Listening, and What Kinds of Issues Did You Come
up with Here? What Did You See? Anyone? Use Your Push to Talk.

Caller: this Is Pat. It Appears There Is Some Kind of Oily Substance
Showing on the Ground Surfaces.

M. Thrasher: Yes, Good Catch. I See Two of Them Right Here. That Could
Bring up Used Oil Issues, Couldn\'t It? Good Catch, Pat. Anybody Else?
Or, Pat, Do You Have Another One? You Know, the Used Oil, We\'ve Got
These Barrels down Here, Too, and You Always Think about Petroleum or
Used Oil, Hazardous Waste Issues When You See Old Drums. Does Anybody
Else Have Any Other Issues That They Identified Here? It\'s Hard. It\'s
Hard to Translate this Stuff into the Real World And, Of Course, That\'s
the Challenge For Us. As You See Big Structures like This, Oftentimes
They May Have Some Kind of Asbestos Lining Material in Them or They May
Have a Little Tarry Material That Has Asbestos Either Inside Them or
Sometimes Outside Them As Well. So Whenever You See These Things, You
May Think about Asbestos as Well. Did You Think of Any Others? Ok.

Caller: What about an Inventory to Know What You\'ve Got?

M. Thrasher: an Inventory, Great. Because a Lot of These Containers ‑‑
Notice this Big One. Look at this Big Container. We Have Some Smaller
Containers. In Fact, There Are Lots of Containers That May Contain
Materials. We Need to Get an Inventory of And That Figure out What Are
the Constituents of That. Good Catch. Any Others Come to Mind? Ok. I
Think with That. I Hate to Rush Through the Last Learning Assessment,
but it Gives You the Idea of What We Need to Do in Terms of Management,
That We Can\'t Just Kind of Feel Overwhelmed by All Of These Laws and
Regulations And Issues. We Need to Go out and Apply the Issues in Real
Life, into the Field and Kind of Get Them Separated, but Then Realize
That There\'s a Lot of Overlap with a Lot of These Issues. I Want to
Invite You Back. We\'re Going to Take a One Week Off and in Two Weeks
We\'ll Come Back for Module 4 in Which We\'re Going to Cover the Clean
Water Act, the Clean Air Act, the Pesticide Laws and Probably a Couple
Other Things. So ‑‑ and We\'re Going to Be ‑‑ Oh, I\'m Sorry, We\'re
Going to Be Doing ‑‑ I Skipped Ahead a Week. We\'re Going to Be Doing
Occupational Safety and Health Act, Department of Transportation and
Those ‑‑ the Clean Water Act and Pesticides And Clean Air Act Are in
Module 5. So That\'s Great. With That, Tony, I\'ll Turn it Back to You.

T. Garrett: and That Completes Module 3 of Our Manager\'s Tool Kit for
Environmental Compliance and Pollution Prevention. We Look Forward to
Having You Join Us at this Same Time, Actual Lay Few Minutes Before The
Hour on March 7 for Module 4. To Let Us Know How Many Were With Us
Today, Please Sign the Roster in Your Viewing Room and Send to It.
Remember, the Primary Source of Information about These Study Materials
That We\'ve Mentioned And Other Resources Will Be on Your Agency\'s
Websites. We Want to Thank Martin Thrasher, Ken Morin and Frank Mills
for All Their Great Work In Designing and Presenting Instruction on
Behalf of the USDA Forest Service and the BLM, Thanks for Watching and
So Long From Phoenix.

Announcer: this Broadcast Has Been a Presentation of the USDA Forest
Service Office of Corporate Training and the BLM National Training
Center.