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Basic RCRA Waste Regulations

For starters, I want to apologize for missing a day of blogging last Thursday. I attended a Heritage RCRA refresher course in downtown Indianapolis and was without internet for most of the day. On the plus side, attending the course gave me ideas for several different blog posts!

Over the coming weeks, I will be singling out some of what I learned and sharing it on here. To begin, I will go over the basic federal requirements set forth by RCRA. It is always important to remember, however, that each state likely has additional requirements that must be met.

The first thing you will want to do is make some basic determinations. On an ongoing basis you should be asking and answering the following questions:

  • In relation to identifying waste streams –
    • What are all the wastes being generated at my facility?
    • What are the different departments generating?
  • In relation to hazardous waste determination –
    • According to the regulatory definitions, which of the wastes being generated are classified as hazardous?
  • In relation to determining regulatory categories –
    • How much waste do you have on site and what is done with it? (see form 8700-12)

Next, you will want to make sure your containers are up to standard. It must be ensured that containers are:

  • In good condition (not rusty, no corrosion, no leaking)
  • Compatible with the waste (you want to make sure the waste will not react with the container)
  • Labeled or marked “hazardous waste”
  • Marked with an accumulation start date
  • Kept closed (as a rule of thumb this means you could tip it over and it wouldn’t leak)
  • Managed to avoid damage and releases
  • Kept free of incompatible wastes; incompatible wastes must never be placed in the same container

The third thing to check is that you are following regulations regarding accumulation areas. For this section you will need to make sure:

  • Ignitable and reactive wastes are at least 50 feet from the property line
  • “No Smoking” signs are posted
  • Incompatible wastes are separated or protected from each other
  • Emergency equipment is available
  • There is adequate aisle space maintained (at least 2½ feet)

Additionally, someone needs to:

  • Inspect container accumulation areas weekly
  • Inspect emergency equipment at least monthly
  • Make shipments every 90 days if you are a large quantity generator
  • Make shipments every 180 days if you are a small quantity generator

Lastly, you must follow the compliance documentation rules. These rules include:

  • Having a contingency plan
  • Having personnel training program and records
  • Documentation of inspections
  • Manifests and LDR forms
  • Biennial Reports
  • Waste analyses/determinations
  • Documented waste minimization program on site

Remember, these guidelines are just a starting point. To ensure compliance you must look into all regulations as they apply to your business, both at federal and state level. Keep checking the blog in the coming weeks for more information about RCRA.

What is a Hazardous Waste Reduction Plan?

According to the EPA, “the National Waste Minimization Program supports efforts that promote a more sustainable society, reduce the amounts of waste generated, and lower the toxicity and persistence of wastes that are generated.” The program focuses on 31 separate “priority chemicals” found in many of our nation’s wastes and products. The primary focus is on eliminating or reducing the quantity of these chemicals that are produced with a secondary focus on recycling them when reduction or elimination cannot be achieved.

There are a few different tools and methods that can be used to aid in the reduction and elimination of these wastes including, “lean manufacturing, energy recovery, Environmental Management Systems (EMS), and green chemistry.” More information about each of these methods can be found on the Heritage website.

A major player in the minimization game is the hazardous waste reduction plan. A hazardous waste reduction plan (often referred to as a waste minimization plan) is required for all hazardous waste generators. General requirements include:

  • Corporate policy statement of support for pollution prevention
  • Description of your pollution prevention planning team(s) makeup, authority, and responsibility
  • Description of how all of the groups (production, laboratory, maintenance, shipping, marketing, engineering, and others) will work together to reduce waste production and energy consumption
  • Plan for publicizing and gaining company-wide support for the pollution prevention program
  • Plan for communicating the successes and failures of pollution prevention programs within your company
  • Description of the processes that produce, use, or release hazardous or toxic materials, including clear definition of the amounts and types of substances, materials, and products under consideration
  • List of treatment, disposal, and recycling facilities and transporters currently used
  • Preliminary review of the cost of pollution control and waste disposal
  • Description of current and past pollution prevention activities at your facility
  • Evaluation of the effectiveness of past and ongoing pollution prevention activities
  • Criteria for prioritizing candidate facilities, processes, and streams for pollution prevention projects

These Hazardous Waste Reduction Plans should be updated annually and there should always be a copy onsite. Additionally, while the points above cover national requirements, many states have additional criteria that must be met. By making sure to keep this plan up-to-date and available you can help prevent EPA violations for your company.

How to Avoid Hazardous Waste Weekly Inspection Violations

Sometime in the next couple of months we will be publishing a new eBook about some common hazardous waste generator violations and how you can go about avoiding them. To tide you over until that comes out though, I’d like to take our post today to write about weekly inspections of hazardous waste storage areas and what these inspections should include.

Inspections should be done once a week on the same day. Mondays and Fridays are typically not good choices because they are often spent catching up from the weekend or readying for the weekend respectively. So, once you pick your inspection day you will need to have both a designated inspector and a back-up because you want to do everything possible to ensure you will never miss a week. Record your weekly inspections in an inspection log.

Inspections should consist of the following at a minimum:

1. Is the area free of debris and other materials?

2. Is the ground clean and dry?

3. Are container tops free of spillage?

4. Is the area free of spills or leaks?

5. Are all of the containers in good condition? (Free of dents and corrosion, not bulging, or otherwise deteriorating?)

6. Are all containers properly closed?

7. Are containers labeled with hazardous waste labels?

8. Is the following information on the labels filled out?

    • Generator name and address
    • Accumulation start date
    • Contents
    • Physical state
    • Hazardous properties

9. Is the information on the labels legible?

10. Have wastes been disposed of within the allowable accumulation time?

11. Are the containers compatible with their contents?

12. Are incompatible wastes stored separately?

13. Is there adequate aisle space?

By making sure to check each of these things every week you will ensure that your company is not responsible for any hazardous waste accidents and ensures that you will not get in trouble with the EPA. Keep checking our blog for a link to the full eBook coming soon!