For many industrial facilities, staying on top of the numerous and ever changing Environmental Protection Agency (EPA) regulations can be difficult and sometimes frustrating. One area that we have seen many facilities having issues with is following the regulations and requirements associated with the Resource Conservation Recovery Act (RCRA). RCRA regulations are those that govern the management of hazardous waste, solid waste, bio-hazardous waste, and universal waste. In this article, we will explore some of the most common mistakes made within general industry when handling, storing, and generating waste streams, and potential violations that are the result of these mistakes.
There are several regulatory requirements regarding labeling of waste areas and containers. All containers storing waste must be marked with the waste designation type that they are associated with (e.g. “Hazardous Waste”). Even tanks and containers storing used oil, including fill pipes used to transfer used oil into underground storage tanks, must be marked with the words “Used Oil.”
This applies to both Primary and Satellite Accumulation Areas. A Satellite Accumulation Area is a waste storage location, near the production area, where up to 55 gallons of hazardous waste can be stored. It is important that all operators are aware of the 55-gallon max limit in the Satellite Accumulation Areas, as the regulation states that the operator is required to be in control of the satellite accumulation points.
It is understandable that employees and supervisors get busy during the day, and new waste or containers being placed in accumulation areas can be overlooked. However, this is a common issue, and is an easy catch for inspectors.
While the accumulation date is technically part of the labeling of waste containers. It is in a section on its own because it is a very common mistake cited by regulators. Accumulation date requirements could be different depending on the type of waste being accumulated; therefore, it is a subject of confusion for many facilities. All hazardous and universal waste containers must be marked with the accumulation date, which is the date that the first item or “drop” of waste began to accumulate in that container, or when the amount of hazardous waste in a Satellite Accumulation container reaches 55 gallons. Large Quantity Generators have a 90-day limit to store hazardous waste, and Small Quantity Generators have a 180-day limit. Very Small Quantity Generators are not subject to those limits unless they exceed their allowable accumulation threshold. Universal waste has a 1-year accumulation time limit.
Large Quantity Generators are required to maintain a Contingency Plan, which specifies locations and processes where waste is generated and handled, personnel responsible for managing waste on site, and all emergency processes needed in case of spill or exposure to the hazardous waste. This plan should be regularly reviewed and updated with correct emergency contact information, locations of waste on site, emergency evacuation maps, and be in coordination with local emergency management agencies.
All personnel involved in hazardous waste handling and management are required to undergo training. Large Quantity Generators are required to do this yearly, while employees at Small Quantity Generator facilities should be thoroughly familiar with proper waste handling and emergency response procedures. In additions, all personnel that deal with loading and unloading of waste and all those that sign the “Hazardous Waste Manifest” be trained according to Department of Transportation (DOT) Hazardous Material requirements.
Hazardous Waste Determination
This is one of the most cited violations in hazardous waste regulations. Facilities should have procedures in place or consider using outside help (i.e. 3rd party) to identify all materials and conduct a waste determination before any waste is generated. Along with this, performing periodic inspections of waste generating processes and storage areas will help ensure continued compliance with federal law. A hazardous waste determination must be made for each waste type and stream at your facility.
There are many more commonly observed mistakes and violations regarding waste management (e.g. recordkeeping, policy implementation, operating procedures, etc.). It would be beneficial, after you read this article, to conduct a walk through of your facility and see if any of these issues are present.
Please contact CTI if you would like assistance with your waste management guidelines and requirements, or if you would like to discuss having a waste determination and/or audit conducted to help your facility’s safety, reputation, and bottom line.