1 Hazardous Waste Management New England Marina Meeting March 30, 2006 U.S. Environmental Protection Agency (EPA) Agency (EPA) Region 1 New England Region

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Hazardous Waste Management Hazardous Waste Management New England Marina MeetingNew England Marina Meeting

March 30, 2006March 30, 2006

U.S. Environmental ProtectionU.S. Environmental Protection Agency (EPA)Agency (EPA)

Region 1 New EnglandRegion 1 New England

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EPA Office of Compliance Sector Notebook EPA Office of Compliance Sector Notebook ProjectProject

“ “Profile of the Water Transportation Industry”, September 1997, EPA/310-R-Profile of the Water Transportation Industry”, September 1997, EPA/310-R-97-00397-003

Where to look for GuidanceWhere to look for Guidance

““Profile of the Shipbuilding and Repair Industry”, November 1997, Profile of the Shipbuilding and Repair Industry”, November 1997,

EPA/310-R-97-008EPA/310-R-97-008

Shipshape Shores and Waters- A Handbook for Marina Operators Shipshape Shores and Waters- A Handbook for Marina Operators and Recreational Boaters, January 2003, EPA-841-B-03-001 and Recreational Boaters, January 2003, EPA-841-B-03-001

www.epa.gov/owow/nps/marinashdbk2003.pdfwww.epa.gov/owow/nps/marinashdbk2003.pdf

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RCRA ComponentsRCRA Components

Subtitle C - Hazardous WasteSubtitle D - Solid Waste

Subtitle I – Underground Storage Tanks

Subtitle C – Cradle to Grave Control of Hazardous

Wastes

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RCRA Subtitle C Goals protect human health and environment from hazards posed by waste disposal,

To ensure that wastes are managed in a manner that is protective of human health and

the environment.

To conserve energy and natural resources via waste recycling and recovery,

To reduce or eliminate the amount of waste generated

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Statutory Definition of Statutory Definition of SolidSolid WasteWaste….any garbage, refuse, sludge from a waste treatment plant, water supply plant or air pollution control facility, and other discarded material, including solid, liquid, semisolid, or contained gaseous material...

SOLID WASTE NEED NOT BE SOLID!

66

Statutory Definition of Statutory Definition of Hazardous WasteHazardous Waste

A “solid waste, or a combination of solid wastes, which because of its quantity, concentration, or physical, chemical, or infectious characteristics may:

1) Cause, or significantly contribute to an increase in mortality or an increase in serious irreversible, or incapacitating reversible, illness or

2) Pose a substantial present or potential hazard to human health or the environment when improperly treated, store transported, or disposed of, or otherwise managed.”

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A Solid waste is hazardous if it:

Exhibits any of the characteristics of a hazardous waste

Has been named as a hazardous waste and listed as such in the regulations Is a mixture containing a listed hazardous waste and a non-hazardous solid waste Is a waste derived from the treatment,

storage, or disposal of a listed waste

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Characteristic Hazardous Wastes

Ignitability Reactivity Corrosivity Toxicity (via TCLP)

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Three Lists of Hazardous Wastes

Non-specific Source Wastes Specific Source Wastes Commercial Chemical Products

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IT IS YOUR RESPONSIBILITY IT IS YOUR RESPONSIBILITY !!!!

As the Owner/Operator you As the Owner/Operator you mustmust know know allall the waste streams you generate and the waste streams you generate and which ones are Hazardous Wastes and, which ones are Hazardous Wastes and, therefore, regulated. therefore, regulated.

Do Hazardous Waste Determinations!!Do Hazardous Waste Determinations!!

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EPA/Federal & State EPA/Federal & State RegulationsRegulations citation: 40 CFR Parts 260-299citation: 40 CFR Parts 260-299 authorized states and their authorized states and their

regulationsregulations

[equivalent or more stringent than [equivalent or more stringent than feds]feds]

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HAZARDOUS WASTE HAZARDOUS WASTE DETERMINATIONSDETERMINATIONS

Generator’s responsibilityGenerator’s responsibility Process knowledgeProcess knowledge AnalysisAnalysis MSDSMSDS Expiration datesExpiration dates Variability of waste streamsVariability of waste streams Cross contaminationCross contamination

1313

Waste Activity NotificationWaste Activity Notificationand Generator Classificationand Generator Classification

Large Quantity >1000Kg (2200#) ……………..…LQGLarge Quantity >1000Kg (2200#) ……………..…LQG(1 Kg Acutely Toxic Wastes)(1 Kg Acutely Toxic Wastes)

Small Quantity 100-1000Kg (220-2200#)………..SQGSmall Quantity 100-1000Kg (220-2200#)………..SQG

Conditionally Exempt SQG <100Kg (220#)…...CESQGConditionally Exempt SQG <100Kg (220#)…...CESQG

Amount Generated =Classification with accumulation Amount Generated =Classification with accumulation limits. limits.

[Volume and Time][Volume and Time]

[There are State Variations- see State Regulations][There are State Variations- see State Regulations]

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Depending on Your Classification, Depending on Your Classification, There Are Requirements for…..There Are Requirements for…..

Record keepingRecord keeping HousekeepingHousekeeping Accumulation Time LimitsAccumulation Time Limits Emergency Preparedness NeedsEmergency Preparedness Needs Employee TrainingEmployee Training

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Specific Container Management Specific Container Management Requirements for ……Requirements for ……

Satellite vs. Non-Satellite Satellite vs. Non-Satellite Storage Areas Storage Areas

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MANAGEMENT REQUIREMENTS MANAGEMENT REQUIREMENTS in CONTAINER STORAGE in CONTAINER STORAGE AREASAREAS LabelingLabeling DatingDating CompatibilityCompatibility Aisle spaceAisle space Open/Closed ContainersOpen/Closed Containers Condition of containersCondition of containers Ignitable waste special requirementsIgnitable waste special requirements

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Satellite Storage…..Satellite Storage….. At or near point of generationAt or near point of generation Under the control of the operator of Under the control of the operator of

the the processprocess Less than 55-gallons of wastes – totalLess than 55-gallons of wastes – total Labeled “Hazardous Waste” or other Labeled “Hazardous Waste” or other

words to describe contentswords to describe contents Keep containers closed, except when Keep containers closed, except when

adding or removingadding or removing

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(Depending on Classification) (Depending on Classification) CONTAINER STORAGE AREA INSPECTIONSCONTAINER STORAGE AREA INSPECTIONS

The owner or operator must inspect The owner or operator must inspect areas where containers are stored, at areas where containers are stored, at least weekly, looking for leaks and least weekly, looking for leaks and for deterioration caused by corrosion for deterioration caused by corrosion or other factors.or other factors.

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Manifesting Wastes Manifesting Wastes RequirementsRequirements

Key to Cradle to GraveKey to Cradle to Grave ManagementManagement

2020

Land Disposal Restriction Land Disposal Restriction NotificationsNotifications

– Protect human health & environmentProtect human health & environment– Minimize reliance on land disposalMinimize reliance on land disposal– Determine if wastes generated are restricted Determine if wastes generated are restricted

from land disposal.from land disposal.– Determine the appropriate treatability group (if Determine the appropriate treatability group (if

any) for restricted wastes.any) for restricted wastes.– Determine if wastes meet treatment standards Determine if wastes meet treatment standards

as generated.as generated.

2121

HAZARDOUS WASTE HAZARDOUS WASTE TRAININGTRAINING Initial trainingInitial training Annual refresher trainingAnnual refresher training Documentation of training program and Documentation of training program and

employee employee training recordstraining records Relevant to job duties performedRelevant to job duties performed Training program led by qualified staffTraining program led by qualified staff document Job titles and Job descriptionsdocument Job titles and Job descriptions

RCRA Training is not OSHA or Emergency RCRA Training is not OSHA or Emergency Response training. RCRA Training develops Response training. RCRA Training develops understanding of appropriate hazardous understanding of appropriate hazardous waste management practices.waste management practices.

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PREPAREDNESS AND PREPAREDNESS AND PREVENTIONPREVENTION

Facilities must be maintained and Facilities must be maintained and operated to minimize the possibility operated to minimize the possibility of a fire, explosion or release of of a fire, explosion or release of hazardous waste or hazardous hazardous waste or hazardous constituents.constituents.

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CONTINGENCY PLANCONTINGENCY PLAN

o must be designed to minimize hazards to human must be designed to minimize hazards to human health and the environment from fires, health and the environment from fires, explosions, or release of hazardous waste or explosions, or release of hazardous waste or hazardous waste constituents.hazardous waste constituents.

o must be carried out immediately.must be carried out immediately.

o describe detailed response actionsdescribe detailed response actions

o provide for arrangements with localsprovide for arrangements with locals

o designate Emergency Coordinator and alternatesdesignate Emergency Coordinator and alternates

o identify emergency equipmentidentify emergency equipment

o identify evacuation plansidentify evacuation plans

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PREPAREDNESS AND PREPAREDNESS AND PREVENTIONPREVENTION

Alarm systemAlarm system Communication devicesCommunication devices ExtinguishersExtinguishers Adequate water supplyAdequate water supply Adequate aisle spaceAdequate aisle space In-place arrangements with locals In-place arrangements with locals

[fire, [fire, police, hospitals]police, hospitals]

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UNIVERSAL WASTEUNIVERSAL WASTE

Universal wastes are widely generated Universal wastes are widely generated and widely recycled hazardous wastes. and widely recycled hazardous wastes. Management standards for these Management standards for these wastes are reduced to facilitate their wastes are reduced to facilitate their recycling.recycling.

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Types of UNIVERSAL WASTETypes of UNIVERSAL WASTE

BatteriesBatteries Mercury containing thermostatsMercury containing thermostats Hazardous waste lampsHazardous waste lamps state specific UWsstate specific UWs

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Universal Waste Universal Waste Requirements..Requirements..

Containerized Containerized Labeled to describe contentLabeled to describe content DatingDating TrainingTraining Record keepingRecord keeping

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RCRA Compliance Evaluation RCRA Compliance Evaluation Inspection OutlineInspection Outline

Unannounced Most are multi-day Physical inspection of

waste storage, generation points and processes, tour of operations and property

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Inspections - continuedInspections - continued

Opening ConferenceOpening Conference the inspector may the inspector may askask

How many employees and shiftsHow many employees and shiftsWhat is your generator statusWhat is your generator statusFor explanation of processes, For explanation of processes,

description of wastes and where description of wastes and where generatedgenerated

Where wastes are stored- satellite and Where wastes are stored- satellite and 90/180 day90/180 day

Inspector will explain how the physical Inspector will explain how the physical inspection will proceedinspection will proceed

Inspector will request availability of Inspector will request availability of documents for records reviewdocuments for records review

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Inspections (continued)…Inspections (continued)…

Documents for Record Reviews includes but is not limited to:

training documents, contingency plans, shipping documents and LDRs, waste determination documentation, inspection logs, Biennial Reports, emergency preparedness information, import/export documentation

3131

Inspections (continued)Inspections (continued)

Close-Out Conference Close-Out Conference Ask for additional information.Ask for additional information.Review areas of concern from walk-Review areas of concern from walk-

through and record review.through and record review.Explain potential follow up.Explain potential follow up.Give facility representatives an Give facility representatives an

opportunity to comment or ask opportunity to comment or ask questions.questions.

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Post-InspectionPost-Inspection

Information Requests Possible Case Development Inspections Inspection Report Several months possible

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Common Marina WastesCommon Marina Wastes

Paint and paint related wastesPaint and paint related wastes Aerosol cansAerosol cans Chemical stripping wastesChemical stripping wastes Abrasive stripping wastesAbrasive stripping wastes Equipment cleaning wastesEquipment cleaning wastes Machine Shop wastesMachine Shop wastes Engine Repair wastesEngine Repair wastes Waste Oils, gear and lube oilsWaste Oils, gear and lube oils

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Common Marina WastesCommon Marina Wastes Transmission fluidTransmission fluid Waste fuelWaste fuel Welding wastesWelding wastes Fiberglass fabrication (solvents, Fiberglass fabrication (solvents,

resins, resins, gelcoat wastes)gelcoat wastes) Leftover raw materials/ Off-spec Leftover raw materials/ Off-spec

productsproducts Acids and alkalisAcids and alkalis Metal finishing wastesMetal finishing wastes

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Pb/acid batteriesPb/acid batteriesBilge water/bilge sludgesBilge water/bilge sludgesEngine test tank watersEngine test tank watersParts washer wasteParts washer wasteRagsRagsAdhesive wastesAdhesive wastes

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Electronics wastesElectronics wastesPesticides and herbicidesPesticides and herbicidesCompressed gas cylindersCompressed gas cylindersFilters- fuel, oil, paint boothFilters- fuel, oil, paint boothAntifreeze (benzene)Antifreeze (benzene)Dust collection system residuesDust collection system residuesSEE LAST PAGE OF HANDOUT FOR SEE LAST PAGE OF HANDOUT FOR

MOREMORE

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Common Areas of Observed Common Areas of Observed ViolationsViolations Hazardous Waste DeterminationsHazardous Waste Determinations Main Hazardous Waste Accumulation Main Hazardous Waste Accumulation

Area and/or Satellite Accumulation Area and/or Satellite Accumulation Area Area Container MismanagementContainer Mismanagement Open ContainersOpen Containers Aisle spaceAisle space Secondary ContainmentSecondary Containment

Unmarked/Unlabeled ContainersUnmarked/Unlabeled Containers Incompatible StorageIncompatible Storage No or Inadequate Land Disposal No or Inadequate Land Disposal

Restriction (LDR) NoticesRestriction (LDR) Notices

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Common Areas of Observed Common Areas of Observed Violations Violations (continued)(continued) No or incomplete Hazardous Waste No or incomplete Hazardous Waste

ManifestsManifests Inadequate Emergency Preparedness Inadequate Emergency Preparedness

and Inadequate/Outdated and Inadequate/Outdated Contingency Contingency PlanPlan

No or Inadequate Hazardous Waste No or Inadequate Hazardous Waste TrainingTraining

No or inadequate In-house No or inadequate In-house InspectionsInspections

Storage > 180 Days, >90 Days w/o Storage > 180 Days, >90 Days w/o PermitPermit

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HW Determination HW Determination ViolationsViolations

What we find...What we find...Mischaracterized or uncharacterized Mischaracterized or uncharacterized

wastes; orwastes; orMaterials that are unused and pending Materials that are unused and pending

disposal not characterizeddisposal not characterized

What we want...What we want...All wastes/materials characterized as All wastes/materials characterized as

soon as they are generated or when soon as they are generated or when they are not going to be usedthey are not going to be used

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HW Determination Violations HW Determination Violations (continued)(continued)

Because...Because... Certain wastes have adverse affect on Certain wastes have adverse affect on

human health and/or the environment - human health and/or the environment - that's why they're regulated. that's why they're regulated.

THE PERSON WHO GENERATES THE THE PERSON WHO GENERATES THE WASTE IS RESPONSIBLE FOR KNOWING WASTE IS RESPONSIBLE FOR KNOWING WHAT IT IS!!!WHAT IT IS!!!

4141

Open Containers Open Containers ViolationsViolationsWhat we find...What we find...

Containers with no cover, no bung, or open Containers with no cover, no bung, or open funnel in bungfunnel in bung

What we want...What we want...All containers of hazardous waste closed All containers of hazardous waste closed

unless materials are being added or unless materials are being added or removedremoved

Because...Because...Materials can be easily spilled from an open Materials can be easily spilled from an open

container. Volatile materials may escape.container. Volatile materials may escape.

4242

Unmarked/Unlabeled Container Unmarked/Unlabeled Container ViolationsViolations

What we find...What we find...Hazardous waste containers that have Hazardous waste containers that have

missing information/no information or missing information/no information or are not datedare not dated

What we want...What we want...Containers with labels that say the Containers with labels that say the

words "Hazardous Waste" and a words "Hazardous Waste" and a description of the waste and the date description of the waste and the date when the waste started to accumulate when the waste started to accumulate (and sometimes more).(and sometimes more).

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Unmarked/Unlabeled Containers Unmarked/Unlabeled Containers (continued)(continued)

Because...Because...A properly labeled container assures A properly labeled container assures

that everyone, including workers and that everyone, including workers and emergency responders, knows that emergency responders, knows that there is a hazardous waste in the there is a hazardous waste in the container and exactly what the waste is. container and exactly what the waste is. Helps avoid mismanagement. Helps avoid mismanagement.

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Unmarked/Unlabeled Containers Unmarked/Unlabeled Containers (continued(continued))

Has caused wastes to be Has caused wastes to be commingledcommingled

Results in no one knowing what the Results in no one knowing what the container holds, for example:container holds, for example:

-person who knew has left the company-person who knew has left the company-person who knows is on vacation when -person who knows is on vacation when

inspector arrivesinspector arrives Can increase need for laboratory Can increase need for laboratory

waste waste stream analysis for waste stream analysis for waste determinationsdeterminations

4545

Satellite Accumulation ViolationsSatellite Accumulation Violations

What we find...What we find...Hazardous waste drums being stored far Hazardous waste drums being stored far

from the place where the wastes are from the place where the wastes are generatedgenerated

...not under anyone's control...not under anyone's control...more than 55-gallons...more than 55-gallons

What we want...What we want...At or near the point of generation and At or near the point of generation and

under the control of the operator, no under the control of the operator, no more than 55-gallons, and container more than 55-gallons, and container meets management requirementsmeets management requirements

4646

Satellite Accumulation Violations Satellite Accumulation Violations (continued)(continued)

BecauseBecauseWe don't want people walking long We don't want people walking long

distances with uncontrolled distances with uncontrolled quantities of hazardous wastequantities of hazardous waste

We want someone watching over We want someone watching over these containers.these containers.

We don't want a lot of material We don't want a lot of material hanging around.hanging around.

4747

Incompatible Waste Storage Incompatible Waste Storage ViolationsViolations

What we find...What we find... Incompatible materials stored next Incompatible materials stored next

to each to each other, or stacked on top on other, or stacked on top on one another.one another.

What we want...What we want... Incompatible materials separated by Incompatible materials separated by

a berm, dike, wall or other physical a berm, dike, wall or other physical barrier.barrier.

Because...Because... KABOOM!!!KABOOM!!!

4848

Hazardous Waste Training ViolationsHazardous Waste Training Violations

Common Issue!Common Issue! Annual training conducted once and Annual training conducted once and

lapseslapses Training is not relevant to duties Training is not relevant to duties

performedperformed Documentation is not maintainedDocumentation is not maintained No plan on who should be trained and No plan on who should be trained and

what they should be trained onwhat they should be trained on Job descriptions not available or…Job descriptions not available or…

4949

Hazardous Waste Training Violations Hazardous Waste Training Violations ((continuedcontinued))

Available, but no longer applicable Available, but no longer applicable for employee - For example:for employee - For example:

- personnel have rotated and job - personnel have rotated and job description no longer fits, ordescription no longer fits, or - job duties have changed and no - job duties have changed and no longer match the job descriptionlonger match the job description

Note: A bad training program will Note: A bad training program will lead to poor waste management!lead to poor waste management!

5050

LDR Notices/Copies LDR Notices/Copies ViolationsViolationsWhat we find…What we find…

Notices not completed at all or Notices not completed at all or incompleteincomplete

Copies are not maintained or available Copies are not maintained or available at the at the facilityfacility

What we want…What we want… Copies of all fully completed notices Copies of all fully completed notices

maintained for 5 maintained for 5 years.years.

Because…Because… It is important that all parties that It is important that all parties that

manage the hazardous waste know that manage the hazardous waste know that it must be treated before disposal.it must be treated before disposal.

5151

Hazardous Waste Manifest Hazardous Waste Manifest ViolationsViolations

What we find…What we find… Photocopies maintained in lieu of actual Photocopies maintained in lieu of actual

recordsrecords Completed signed copy not maintained Completed signed copy not maintained

(most (most important manifest document!)important manifest document!)

What we want…What we want… Copies of manifests maintained for 3 years.Copies of manifests maintained for 3 years. Copies of exception reports maintained.Copies of exception reports maintained.

Because…Because… This is the cradle to grave tracking system This is the cradle to grave tracking system

that that ensures that hazardous wastes safely ensures that hazardous wastes safely reach a reach a designated facility.designated facility.

5252

Contingency Plan Contingency Plan ViolationsViolations

What we find...What we find...No contingency plan No contingency plan Information in plan is old, incorrect telephone Information in plan is old, incorrect telephone

numbers or procedures; andnumbers or procedures; andCopies not sent to the appropriate parties.Copies not sent to the appropriate parties.People listed in the plan have leftPeople listed in the plan have leftLocal officials have not been sent copies of the planLocal officials have not been sent copies of the planEmergency equipment descriptions and locations Emergency equipment descriptions and locations

are missing or outdatedare missing or outdatedPlan does not address required incidents, for Plan does not address required incidents, for

example: example: - spills- spills - explosions- explosions

- fires- fires - releases- releases

5353

Contingency Plan Violations Contingency Plan Violations (continued)(continued)

What we want...What we want...Name and telephone number of facility person in Name and telephone number of facility person in

charge of emergency response (plus back-up)charge of emergency response (plus back-up)Telephone numbers of local authorities (e.g., fire, Telephone numbers of local authorities (e.g., fire,

hospital, police, DEP, NRC), response contractorhospital, police, DEP, NRC), response contractorProcedures on what to do in the case of a fire, Procedures on what to do in the case of a fire,

flood, leak, spill, and for loading/unloading waste flood, leak, spill, and for loading/unloading waste at your facilityat your facility

Lists, locations, and capability of emergency Lists, locations, and capability of emergency equipment; equipment;

have it readily available and send copies to all local have it readily available and send copies to all local authoritiesauthorities

Evacuation plan and evacuation routesEvacuation plan and evacuation routes

5454

Contingency Plan Violations Contingency Plan Violations (continued)(continued)

Because...Because...It should be clear to all affected It should be clear to all affected

employees and anyone responding to employees and anyone responding to an emergency what types of materials an emergency what types of materials are at the facility, what to do, where to are at the facility, what to do, where to go, and who to call.go, and who to call.

5555

Weekly/Daily Inspection ViolationsWeekly/Daily Inspection Violations

What we find…What we find… No weekly/daily inspections/missed No weekly/daily inspections/missed

inspectionsinspections Not all areas inspectedNot all areas inspected Inspections/corrective actions not Inspections/corrective actions not

documenteddocumented

5656

Weekly/Daily Inspection Violations Weekly/Daily Inspection Violations (continued)(continued)

What we want…What we want… Inspections of satellite and main Inspections of satellite and main

accumulation areasaccumulation areas- weekly for containers- weekly for containers- Daily for tanks- Daily for tanks

Inspections of tanks- container management Inspections of tanks- container management standards, leaking? or deterioration?standards, leaking? or deterioration?

Paper documentation for each area including Paper documentation for each area including comments and corrective actions taken comments and corrective actions taken

Minimum for most states, except for MAMinimum for most states, except for MA ****(It’s ok to document a problem.)****(It’s ok to document a problem.)

5757

Weekly/Daily Inspection Violations Weekly/Daily Inspection Violations (continued)(continued)

Because…Because…It’s important to conduct a regular It’s important to conduct a regular

check to ensure that all management check to ensure that all management requirements are met and that no requirements are met and that no leaking or deterioration has occurred.leaking or deterioration has occurred.

5858

Storage for Greater than 90 or Storage for Greater than 90 or 180-Days180-Days

What we find…What we find… Forgotten drumsForgotten drums Non-compliant satellitesNon-compliant satellitesJust didn’t shipJust didn’t ship

What we want…What we want… Wastes regularly moved off-site in less than Wastes regularly moved off-site in less than

90-90- days or 180-days.days or 180-days.

Because…Because… We don’t want large quantities of hazardous We don’t want large quantities of hazardous

waste accumulating for long periods of time waste accumulating for long periods of time without additional precautions of a permit (i.e., without additional precautions of a permit (i.e.,

closure plans and financial assurance).closure plans and financial assurance).

5959

EPA EnforcementEPA Enforcement

Goals of Enforcement

Environmental Protection Correction of Violations Deterrence Fairness – level playing field Punishment

6060

Enforcement ResponseEnforcement Response

Informal Actions

NOVs

No penalties associated

List violations

Schedules for Return to Compliance

6161


Formal Administrative Orders

Penalty Actions ($32,500/day/violation)

Require Corrective Actions

Requires Return to Compliance

SEPs

6262


Civil Judicial Actions

Referrals to DOJ

Lawsuit in Federal District Court

Can take several years to complete

6363


Criminal Actions

Knowing, willful, or negligent acts Fines, imprisonment for

individuals

6464


RCRA cases can range from $10K to multi-million dollars in penalties and require extensive corrective measures

6565

Questions:Questions:

Susann NachmannSusann Nachmann 617-918-1871617-918-1871

Richard PiligianRichard Piligian 617-918-1757617-918-1757