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Case Scenario #1


You are the chief Environmental, Safety and Health (EHS) professional for your small municipallity and it is the first work day after the Christmas Holiday. You are settling in and looking forward to the typically nice and quiet period until the end of the year. So quiet of a time it generally is that you decided, for once, to let the rest of your staff enjoy the holidays with friends and family. The day has gone well, as you had expected and it is a little after noon when you receive your first phone call of the day.


The voice on the other end of the phone is a familiar one and after you exchange season pleasantries you are informed that there was a car fire in the City Hall parking lot and during the fire the car battery was destroyed, spilling its contents on the ground and possibly into the stormwater system.


Does this present an environmental hazard and if so does it need to be cleaned up? Who should do the clean up?


How should any material recovered from this site be disposed of? Can it be put into the city landfill? What if it is mixed with sand or an absorbent material such as kitty litter?


What potential hazards, if any, does this situation present to the stormwater system? Who, if anyone, needs to be notified?


Case Scenario #2


One of your personnel discovers containers placed in the wood line at the edge of your facilities property. The containers (3-55 gallon drums and some old 5-gallon paint pails containing some dried and some still wet latex paint; in addition there are several cans that are labeled as solvent based paint) are too old to determine the rightful owner or the contents within. One 55 gallon drum is sealed yet it appears to be “bulging”. The other one has no more than one inch of residue remaining on the bottom. The third 55 gallon drum is labelled “mirror backing paint – contains lead pigment”. It’s outside condition is good, but it appears to be almost 50% full.


 For the one 55-gallon drum that is open, according to RCRA is it empty? Provide the regulatory citation (section) for your response.



  1. What should be done with the bulging 55 gallon container and the mirror back paint drum?
    What should be done with the old paint cans – the latex and solvent based cans?