Chuck Kroeger

April 17, 2014 | 2014 GREATER OZARKS ENVIRONMENTAL SUMMIT

HazWaste: Ten RCRA Compliance Issues that Can Trip You Up

Waste Determination

1% = 10,000 ppm

10.0 ppm = 0.001 %

Employee training

Large Quantity Generator

Requires formal training plan

“ensures the facility's compliance with the requirements” 40 CFR 265

Personnel Training Content

• Hazardous waste management procedures

• (i) Procedures for using, inspecting, repairing, and replacing facility emergency and monitoring equipment;

• (ii) Key parameters for automatic waste feed cut-off systems;• (iii) Communications or alarm systems;• (iv) Response to fires or explosions;• (v) Response to ground-water contamination incidents; and• (vi) Shutdown of operations.

Personnel Training

• Must be trained within 6 months of employment or new position

• Must not work unsupervised

until trained

• Annual review

Personnel Training Documentation

• (1) The job title for each position at the facility related to hazardous waste management, and the name

• (2) A written job description - must include the requisite skill, education, or other qualifications, and duties of facility personnel assigned to each position;

• (3) A written description of the type and amount of both introductory and continuing training

• (4) Records that document that the training or job experience has been given to, and completed by, facility personnel.

• If all not documented - in violation

Employee training

Small Quantity Generator

Ensure employees familiar with waste handling and spill procedures

Ignitable waste stored within 50’ of the property line

Large Quantity Generator Requirement

Storage of incompatible waste

Appendix V 40 CFR 265

Fuming drum

40 CFR Appendix V

Storage of incompatible waste

Spent acids/spent corrosives

Oxidizers/acids

Alcohols/strong acids

Aisle space

Unobstructed movement of:

• personnel • fire protection equipment • spill control equipment • decontamination equipment

Inspect Containers

At least Weekly

Inspections -

• Areas where containers are stored

• Look for leaking containers and for deterioration of containers

• Containers in good condition –─ Not dented – raised support band ─ Not creased─ Not severely rusted

Post emergency information near phone

SQG requirement

•

Name and contact information for emergency coordinator

• Location of fire extinguishers and spill control equipment

• Emergency phone numbers - 911

Waste minimization

LQG – program in place

SQG – Good faith effort

40 CFR 262.27 Waste minimization certification

Waste Minimization

Solid Waste Disposal Act - the manifest is required to contain a certification by the generator that —

(1) the generator of the hazardous waste has a program in

place to reduce the volume or quantity and toxicity of such

waste to the degree determined by the generator to be economically

practicable; and

(2) the proposed method of treatment, storage, or disposal

is that practicable method currently available to the generator

which minimizes the present and future threat to human

health and the environment.

Fine print on Manifest

• I certify that the waste minimization statement identified in 40 CFR 262.27(a) (if I am a large quantity generator) or (b) (if I am a small quantity generator) is true

Here’s what 40 CFR 262.27 says

• (a) “I am a large quantity generator. I have a program in place to reduce the volume and toxicity of waste generated to the degree I have determined to be economically practicable and I have selected the practicable method of treatment, storage, or disposal currently available to me which minimizes the present and future threat to human health and the environment;” or

• (b) “I am a small quantity generator. I have made a good faith effort to minimize my waste generation and select the best waste management method that is available to me and that I can afford.”

Notification of Hazardous Waste Activity

form update

5.262(2)(A)3.B

Orphan waste

• Cabinets• Stairwells• Lofts

The Short Story – Pay attention to the details and Be Happy

Contact

• Chuck Kroeger, Environmental Scientist• (417) 831-7900• (417) 343-9335• ckroeger@geoengineers.com