B. Recoupment, an important part of an installation's hazardous materials operation, has three
primary objectives: (1) minimizing hazardous waste; (2) minimizing loss of stock; and (3)
maintaining product quality. Returning NRFI items to stock through recoupment, rather than
relegating them to disposal for sale as excess personal property or as hazardous waste, is a
positive and specific action directed toward decreasing stock loss and hazardous waste generated
by installation operations. An effective recoupment operation must have fast turnaround of
damaged stock with no loss of product quality.
C. A recoupment operation depends on a variety of factors: recoupment processes, the physical
state of the material (e.g., solid, liquid, powder), the hazards associated with the material (e.g.,
flammability, reactivity, corrosivity, toxicity), and the type and size of the package. Actual
recoupment operations that can safely be performed depend on the types of transfer, materials
handling, and safety equipment available and on the design of recoupment facilities. Relabeling
the hazardous material poses little threat to personnel health. However, operations that involve
open packages of hazardous materials (e.g., transfer of hazardous materials to new packages,
handling damaged/leaking packages of hazardous materials) pose a risk to personnel, the
environment, and the facilities. The degree of risk is a function of the material and its associated
hazards. The probability of a hazardous material mishap resulting in a serious incident (e.g.,
commingling of incompatible materials, fire, explosion, toxic fume generation,
environmental/personnel exposure) is higher during recoupment operations than during normal
operations because open packages of hazardous materials are involved. Strict procedural and
engineering controls must be incorporated into recoupment operations to prevent any damage or
injury to personnel, facilities, or the environment.
4.29 Impact of Federal Regulations. Recoupment personnel must be aware of pertinent
Federal regulations and their impact on recoupment operations. In addition to the requirements
identified in this publication, recoupment personnel must be particularly alert to the following:
A. To comply with the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and Title
40 CFR, concerning pesticides, manufacturers and formulators must submit pesticide labels to
EPA for registration before distribution of the pesticide; use of any other label for distribution is
unlawful. Recoupment of damaged or deteriorated pesticide labels, packs, or packaging cannot
be performed. NRFI pesticides must be returned to the manufacturer for recycling or must be
processed through the DRMO as waste.
B. Radioactive substances exceeding exempt concentrations require licensing by the NRC
according to Title 10 CFR. Radioactive materials not licensed by the NRC may require licensing
by the DoD component. If a licensed radioactive material is damaged, emergency procedures
and reporting should be implemented. No sealed radioactive material source shall be opened.
All maintenance operations with radioactive materials must be licensed or authorized by NRC or
the appropriate service licensing official.
C. Management of hazardous waste generated during recoupment operations, including
contaminated equipment and residues from damaged containers, must conform with regulations
in Title 40 CFR concerning hazardous waste disposal. Hazardous wastes must either be turned in
to the DRMO or disposed of by service contract with a licensed commercial firm or through
interservice/interagency support agreements.
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