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Beyond RCRA - 101
NCDENR - Division of Waste ManagementHazardous Waste Section
Compliance Branch
1
North CarolinaDepartment of Environment amp Natural Resources
Division of Waste ManagementHazardous Waste Section
Compliance Branch
Phil OrozcoEnvironmental Senior Specialist
Phone 919-212-2501Email philorozconcdenrgov
Primary Areas Research Triangle Park Durham and Chapel Hill NC 2
Communication is Key
With your State Inspector The EHampS Director amp Staff Department Heads ProfessorsPrincipal Investigators
ldquoSome Men You Just Canrsquot Reachrdquo - CHL
Lab Managers(Especially in graduate student labs)
Your General Services Staff Your HW Contractor
Violations Involving the Basics
Graduate Student Labs ndash SAAs
General Services ndash UW lamps Used Oil Aerosol Cans Paint Shops Power Plants Grounds-Keeping
Contractors ndash Donrsquot rely too heavily on HW vendors Keep an eye on Construction amp Demolition Contractors
Possible Remedies When necessary find a bilingual student to
serve as the lab safety manager When making pick-ups of HW at all locations
have your staff person do a quick audit Periodically do an audit of general services ndash
donrsquot wait for pick-ups of HW Demolition ndash get your inspector to OK any
temporary SAAs or 90180 - day storage areas
Rules Announced But Not Yet Proposed
Description of rule Action Scheduled date
Improvements to the hazardous waste generator regulations
NPRM 1014
Management standards for hazardous waste pharmaceuticals
NPRM 1214
Revisions to the hazardous waste import and export requirements
NPRM 215
Revisions to LDR treatment standards and recycling requirements for spent petroleum hydrotreating and hydrorefining catalyst
NPRM DND
Revisions to the biennial report NPRM DND
Hazardous waste requirements for managing waste retail products
NPRM DND
DND = date not determined LDR = land disposal restrictions NODA = notice of data availability NPRM = notice of proposed UST = underground storage tank
Proposed Rules to Be Finalized
Description of rule Action Scheduled date
Revisions to the definition of solid waste
Final rule 0714
Revisions to secondary containment and operator training requirements for USTs
Final rule 1014
Standards for Subtitle CD management of utility coal combustion residues
Final rule 1214
UST = underground storage tank CD = construction amp demolition
RCRA Authorization
Authorized RCRA Program Not RCRA Authorization
All States except AK amp IA Alaska
Iowa
District of Columbia Puerto Rico
Guam The Virgin Islands
American Samoa
Commonwealth of the Northern Marianna Islands
Tribal Lands (unless the State specifically receives authorization for them within its borders)
RCRA Authorized StatesCan be more strict amp broad in its regulation of HW then the Federal program Examples includeAnnual hazardous waste report instead of biennial
State-specific forms for the Notification of Regulated Waste Activity (EPA 8700-12 Form)
State-specific HW Codes
Containment requirements for HW in 90-Day amp 180-Day ndash EPA requires containment for permitted facilities only
Time limits for accumulation of hazardous waste in Satellite Accumulation Areas
Where is the Academic Labs Rule in Effect
Academic Labs Rule ndash Subpart K
In 2014 86 facilities are currently operating under Subpart Kbull 56 are collegesuniversitiesbull 10 are teaching hospitals onlybull 13 are non-profit research institute onlybull 2 are collegeuniversity w a teaching hospitalbull 5 are teaching hospital and non-profit research
institute
Where is the Solvent Contaminated Wipe Rule in Effect
Summary of EPArsquosAudit Policy
Revised Policy1048708 65 FR 19617 - Effective May 11 20001048708 wwwepagovcomplianceincentivesauditingauditpolicyhtml
Incentives under Policy Penalty mitigation
No recommendation for criminal prosecution
No routine requests for audit reports
Conditions of the Audit Policy Entities that satisfy all the following conditions
are eligible for 100 penalty mitigation EPA retains its discretion to collect any economic benefit that may have been
realized as a result of non-compliance
Entities that satisfy all but the first condition -- systematic discovery -- are eligible for 75 penalty mitigation
Condition
Number
Short-Hand Summary ofAudit Policy Conditions
1
Systematic Discovery of the violation through an environmental audit or a compliance management system
2Voluntary Discovery in other words it is not through a legally required monitoring sampling or auditing procedure
3
Prompt Disclosure in writing to EPA within 21 days of discovery or any shorter time required by law
4 Independent Discovery and Disclosure
5
Correction and Remediation within 60 days in most cases from date of discovery
6 Prevent recurrence of a violation
7
Repeat violations are not eligible for mitigation under the Audit Policy
8 Certain violations are not eligible
9 Cooperation by the disclosing entity is required
Conditions of Policy
1 Systematic Discovery of the violation through an environmental audit or a compliance management system
2 Voluntary Discovery that is not through a legally required monitoring sampling or auditing procedure
Conditions of Policy cont
3 Prompt disclosure in writing to EPA within 21 days of discovery or any shorter time required by law
bull Discovery occurs when any officer director employee or agent of the facility has an objectively reasonable basis for believing that a violation has or may have occurred
Conditions of Policy cont
4 Independent discovery and disclosure before EPA likely would have identified the violation through its own investigation or based on information from a third party
5 Correction and remediation within 60 days in most cases from date of discovery
Conditions of Policy cont
6 Prevent recurrence of violation
7 Repeat violations are not eligible that is violations that occurred within the past 3 years at the same facility or as part of a pattern of violations within the past 5 years at facilities owned or operated by the same company
Conditions of Policy cont
8 Certain violations are not eligible -- those that result in serious actual harm that may have presented an imminent and substantial endangerment or that violate specific terms of an administrative or judicial order or consent agreement
9 Cooperation by the disclosing entity is required
State Self Reporting Policy
Your state may have a self reporting policy similar to the federal policy
May need to notify through both EPA and your State to receive any penalty mitigation
Things you need to do Get the inspector in amp out as quickly as
possible
Keep your records neat and orderly
Ensure records are available for review bull Location of records must be known by several
people
Audit those that transport and receive your waste (HW UW E-waste amp non-haz)
Read the Inspectorrsquos Report
SQG vs LQG Paperwork RequirementsSmall Quantity Generator
bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with
local emergency authorities
bull Emergency Info posted by a phone
bull Employees must be thoroughly familiarhellip
Large Quantity Generator
bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with
local emergency authoritiesbull Contingency Plan
bull Documented RCRA Training job descriptions
bull Biennial Reportbull Waste Min Plan (Written)
Waste minimization certification for both SQGs amp LQGs
Common Violation
Item 13 Waste Codesbull Enter up to six federalstate
waste codes to describe each waste stream identified in Item 9bndash State waste codes that are
not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste
ndash No specific required order or hierarchy for state and federal waste codes
Manifests vs LDRs
Manifests and Land Disposal Restrictions are inter-connected but separate rules
40 CFR 26220 Appendix vs 2689(b)
Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005
Manifests HW Storage Limits SQGs only
40 CFR 26234(e)Allows storage of HW for 270 days when being
transported gt 200 miles an additional 90 days
40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit
LQG 90-Day Storage Limit
40 CFR 26234(b)
Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo
Exceeding the time limit is a MAJOR violation
Hospitals
Hazardous Waste Pharmaceutical Management Standards
The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities
ndash Proposed rule anticipated publication date August 2013
Hazardous Waste Pharmaceutical Management Standards
For more information
httpwwwepagovoswhazardgenerationpharmaceuticalshtm
Waste Generated at Hospitals
Using a MSDS for Waste Determinations
OSHA regs do not require manufacturers to identify constituents present in material at concentrations below
ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)
The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS
Salts and Esters not P-listed
If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated
Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products
EPA Guidance RO12155
Epinephrine Salts
P042 listing (Epinephrine) does not apply to Epinephrine salts
Most or all Epi-pens are Epinephrine salts
EPA Guidance RO14788
Using CAS Number for Waste Determinations
Formaldehyde (CAS No 50-00-0)ndash U122 when unused
If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of
formaldehyde when disposed of amp = U122
EPA Guidance RO13658
Silver Recovery Units
Low Level Mixed Waste - LLMW
Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste
Only applies to facilities with NRC permits Notification is required if conditional
exemption is claimed Read the Rule There are conditions to to
be met
Conditions for LLMW
Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N
Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste
10 Common RCRA Violations
10
Emergency Arrangements (esp Small Quantity Generators)
Arrangements with Local Authorities
26537
The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations
SQG
LQG
Arrangements with Local Authorities(40 CFR 26537)
Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams
Layout of the facilityProperties amp associated hazards of
hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes
Arrangements with Local Authorities - Hospitals
Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the
facilityndash The types of injuries or illnesses which could result
from fires explosions or releases at the facility
9
Hazardous Waste not in Containers
8
Documentation
Common ViolationsLQG
ndash Job Descriptionsndash LQG contingency plan
Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area
LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage
area(s) documented
Job Descriptions A written job description for each position
ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position
ndash Duties describe the HW responsibilities of the individual holding that position
ndash Match name(s) to current title
Container Inspection Records
The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other
factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)
SQGLQG
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
North CarolinaDepartment of Environment amp Natural Resources
Division of Waste ManagementHazardous Waste Section
Compliance Branch
Phil OrozcoEnvironmental Senior Specialist
Phone 919-212-2501Email philorozconcdenrgov
Primary Areas Research Triangle Park Durham and Chapel Hill NC 2
Communication is Key
With your State Inspector The EHampS Director amp Staff Department Heads ProfessorsPrincipal Investigators
ldquoSome Men You Just Canrsquot Reachrdquo - CHL
Lab Managers(Especially in graduate student labs)
Your General Services Staff Your HW Contractor
Violations Involving the Basics
Graduate Student Labs ndash SAAs
General Services ndash UW lamps Used Oil Aerosol Cans Paint Shops Power Plants Grounds-Keeping
Contractors ndash Donrsquot rely too heavily on HW vendors Keep an eye on Construction amp Demolition Contractors
Possible Remedies When necessary find a bilingual student to
serve as the lab safety manager When making pick-ups of HW at all locations
have your staff person do a quick audit Periodically do an audit of general services ndash
donrsquot wait for pick-ups of HW Demolition ndash get your inspector to OK any
temporary SAAs or 90180 - day storage areas
Rules Announced But Not Yet Proposed
Description of rule Action Scheduled date
Improvements to the hazardous waste generator regulations
NPRM 1014
Management standards for hazardous waste pharmaceuticals
NPRM 1214
Revisions to the hazardous waste import and export requirements
NPRM 215
Revisions to LDR treatment standards and recycling requirements for spent petroleum hydrotreating and hydrorefining catalyst
NPRM DND
Revisions to the biennial report NPRM DND
Hazardous waste requirements for managing waste retail products
NPRM DND
DND = date not determined LDR = land disposal restrictions NODA = notice of data availability NPRM = notice of proposed UST = underground storage tank
Proposed Rules to Be Finalized
Description of rule Action Scheduled date
Revisions to the definition of solid waste
Final rule 0714
Revisions to secondary containment and operator training requirements for USTs
Final rule 1014
Standards for Subtitle CD management of utility coal combustion residues
Final rule 1214
UST = underground storage tank CD = construction amp demolition
RCRA Authorization
Authorized RCRA Program Not RCRA Authorization
All States except AK amp IA Alaska
Iowa
District of Columbia Puerto Rico
Guam The Virgin Islands
American Samoa
Commonwealth of the Northern Marianna Islands
Tribal Lands (unless the State specifically receives authorization for them within its borders)
RCRA Authorized StatesCan be more strict amp broad in its regulation of HW then the Federal program Examples includeAnnual hazardous waste report instead of biennial
State-specific forms for the Notification of Regulated Waste Activity (EPA 8700-12 Form)
State-specific HW Codes
Containment requirements for HW in 90-Day amp 180-Day ndash EPA requires containment for permitted facilities only
Time limits for accumulation of hazardous waste in Satellite Accumulation Areas
Where is the Academic Labs Rule in Effect
Academic Labs Rule ndash Subpart K
In 2014 86 facilities are currently operating under Subpart Kbull 56 are collegesuniversitiesbull 10 are teaching hospitals onlybull 13 are non-profit research institute onlybull 2 are collegeuniversity w a teaching hospitalbull 5 are teaching hospital and non-profit research
institute
Where is the Solvent Contaminated Wipe Rule in Effect
Summary of EPArsquosAudit Policy
Revised Policy1048708 65 FR 19617 - Effective May 11 20001048708 wwwepagovcomplianceincentivesauditingauditpolicyhtml
Incentives under Policy Penalty mitigation
No recommendation for criminal prosecution
No routine requests for audit reports
Conditions of the Audit Policy Entities that satisfy all the following conditions
are eligible for 100 penalty mitigation EPA retains its discretion to collect any economic benefit that may have been
realized as a result of non-compliance
Entities that satisfy all but the first condition -- systematic discovery -- are eligible for 75 penalty mitigation
Condition
Number
Short-Hand Summary ofAudit Policy Conditions
1
Systematic Discovery of the violation through an environmental audit or a compliance management system
2Voluntary Discovery in other words it is not through a legally required monitoring sampling or auditing procedure
3
Prompt Disclosure in writing to EPA within 21 days of discovery or any shorter time required by law
4 Independent Discovery and Disclosure
5
Correction and Remediation within 60 days in most cases from date of discovery
6 Prevent recurrence of a violation
7
Repeat violations are not eligible for mitigation under the Audit Policy
8 Certain violations are not eligible
9 Cooperation by the disclosing entity is required
Conditions of Policy
1 Systematic Discovery of the violation through an environmental audit or a compliance management system
2 Voluntary Discovery that is not through a legally required monitoring sampling or auditing procedure
Conditions of Policy cont
3 Prompt disclosure in writing to EPA within 21 days of discovery or any shorter time required by law
bull Discovery occurs when any officer director employee or agent of the facility has an objectively reasonable basis for believing that a violation has or may have occurred
Conditions of Policy cont
4 Independent discovery and disclosure before EPA likely would have identified the violation through its own investigation or based on information from a third party
5 Correction and remediation within 60 days in most cases from date of discovery
Conditions of Policy cont
6 Prevent recurrence of violation
7 Repeat violations are not eligible that is violations that occurred within the past 3 years at the same facility or as part of a pattern of violations within the past 5 years at facilities owned or operated by the same company
Conditions of Policy cont
8 Certain violations are not eligible -- those that result in serious actual harm that may have presented an imminent and substantial endangerment or that violate specific terms of an administrative or judicial order or consent agreement
9 Cooperation by the disclosing entity is required
State Self Reporting Policy
Your state may have a self reporting policy similar to the federal policy
May need to notify through both EPA and your State to receive any penalty mitigation
Things you need to do Get the inspector in amp out as quickly as
possible
Keep your records neat and orderly
Ensure records are available for review bull Location of records must be known by several
people
Audit those that transport and receive your waste (HW UW E-waste amp non-haz)
Read the Inspectorrsquos Report
SQG vs LQG Paperwork RequirementsSmall Quantity Generator
bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with
local emergency authorities
bull Emergency Info posted by a phone
bull Employees must be thoroughly familiarhellip
Large Quantity Generator
bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with
local emergency authoritiesbull Contingency Plan
bull Documented RCRA Training job descriptions
bull Biennial Reportbull Waste Min Plan (Written)
Waste minimization certification for both SQGs amp LQGs
Common Violation
Item 13 Waste Codesbull Enter up to six federalstate
waste codes to describe each waste stream identified in Item 9bndash State waste codes that are
not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste
ndash No specific required order or hierarchy for state and federal waste codes
Manifests vs LDRs
Manifests and Land Disposal Restrictions are inter-connected but separate rules
40 CFR 26220 Appendix vs 2689(b)
Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005
Manifests HW Storage Limits SQGs only
40 CFR 26234(e)Allows storage of HW for 270 days when being
transported gt 200 miles an additional 90 days
40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit
LQG 90-Day Storage Limit
40 CFR 26234(b)
Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo
Exceeding the time limit is a MAJOR violation
Hospitals
Hazardous Waste Pharmaceutical Management Standards
The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities
ndash Proposed rule anticipated publication date August 2013
Hazardous Waste Pharmaceutical Management Standards
For more information
httpwwwepagovoswhazardgenerationpharmaceuticalshtm
Waste Generated at Hospitals
Using a MSDS for Waste Determinations
OSHA regs do not require manufacturers to identify constituents present in material at concentrations below
ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)
The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS
Salts and Esters not P-listed
If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated
Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products
EPA Guidance RO12155
Epinephrine Salts
P042 listing (Epinephrine) does not apply to Epinephrine salts
Most or all Epi-pens are Epinephrine salts
EPA Guidance RO14788
Using CAS Number for Waste Determinations
Formaldehyde (CAS No 50-00-0)ndash U122 when unused
If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of
formaldehyde when disposed of amp = U122
EPA Guidance RO13658
Silver Recovery Units
Low Level Mixed Waste - LLMW
Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste
Only applies to facilities with NRC permits Notification is required if conditional
exemption is claimed Read the Rule There are conditions to to
be met
Conditions for LLMW
Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N
Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste
10 Common RCRA Violations
10
Emergency Arrangements (esp Small Quantity Generators)
Arrangements with Local Authorities
26537
The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations
SQG
LQG
Arrangements with Local Authorities(40 CFR 26537)
Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams
Layout of the facilityProperties amp associated hazards of
hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes
Arrangements with Local Authorities - Hospitals
Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the
facilityndash The types of injuries or illnesses which could result
from fires explosions or releases at the facility
9
Hazardous Waste not in Containers
8
Documentation
Common ViolationsLQG
ndash Job Descriptionsndash LQG contingency plan
Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area
LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage
area(s) documented
Job Descriptions A written job description for each position
ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position
ndash Duties describe the HW responsibilities of the individual holding that position
ndash Match name(s) to current title
Container Inspection Records
The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other
factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)
SQGLQG
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
Communication is Key
With your State Inspector The EHampS Director amp Staff Department Heads ProfessorsPrincipal Investigators
ldquoSome Men You Just Canrsquot Reachrdquo - CHL
Lab Managers(Especially in graduate student labs)
Your General Services Staff Your HW Contractor
Violations Involving the Basics
Graduate Student Labs ndash SAAs
General Services ndash UW lamps Used Oil Aerosol Cans Paint Shops Power Plants Grounds-Keeping
Contractors ndash Donrsquot rely too heavily on HW vendors Keep an eye on Construction amp Demolition Contractors
Possible Remedies When necessary find a bilingual student to
serve as the lab safety manager When making pick-ups of HW at all locations
have your staff person do a quick audit Periodically do an audit of general services ndash
donrsquot wait for pick-ups of HW Demolition ndash get your inspector to OK any
temporary SAAs or 90180 - day storage areas
Rules Announced But Not Yet Proposed
Description of rule Action Scheduled date
Improvements to the hazardous waste generator regulations
NPRM 1014
Management standards for hazardous waste pharmaceuticals
NPRM 1214
Revisions to the hazardous waste import and export requirements
NPRM 215
Revisions to LDR treatment standards and recycling requirements for spent petroleum hydrotreating and hydrorefining catalyst
NPRM DND
Revisions to the biennial report NPRM DND
Hazardous waste requirements for managing waste retail products
NPRM DND
DND = date not determined LDR = land disposal restrictions NODA = notice of data availability NPRM = notice of proposed UST = underground storage tank
Proposed Rules to Be Finalized
Description of rule Action Scheduled date
Revisions to the definition of solid waste
Final rule 0714
Revisions to secondary containment and operator training requirements for USTs
Final rule 1014
Standards for Subtitle CD management of utility coal combustion residues
Final rule 1214
UST = underground storage tank CD = construction amp demolition
RCRA Authorization
Authorized RCRA Program Not RCRA Authorization
All States except AK amp IA Alaska
Iowa
District of Columbia Puerto Rico
Guam The Virgin Islands
American Samoa
Commonwealth of the Northern Marianna Islands
Tribal Lands (unless the State specifically receives authorization for them within its borders)
RCRA Authorized StatesCan be more strict amp broad in its regulation of HW then the Federal program Examples includeAnnual hazardous waste report instead of biennial
State-specific forms for the Notification of Regulated Waste Activity (EPA 8700-12 Form)
State-specific HW Codes
Containment requirements for HW in 90-Day amp 180-Day ndash EPA requires containment for permitted facilities only
Time limits for accumulation of hazardous waste in Satellite Accumulation Areas
Where is the Academic Labs Rule in Effect
Academic Labs Rule ndash Subpart K
In 2014 86 facilities are currently operating under Subpart Kbull 56 are collegesuniversitiesbull 10 are teaching hospitals onlybull 13 are non-profit research institute onlybull 2 are collegeuniversity w a teaching hospitalbull 5 are teaching hospital and non-profit research
institute
Where is the Solvent Contaminated Wipe Rule in Effect
Summary of EPArsquosAudit Policy
Revised Policy1048708 65 FR 19617 - Effective May 11 20001048708 wwwepagovcomplianceincentivesauditingauditpolicyhtml
Incentives under Policy Penalty mitigation
No recommendation for criminal prosecution
No routine requests for audit reports
Conditions of the Audit Policy Entities that satisfy all the following conditions
are eligible for 100 penalty mitigation EPA retains its discretion to collect any economic benefit that may have been
realized as a result of non-compliance
Entities that satisfy all but the first condition -- systematic discovery -- are eligible for 75 penalty mitigation
Condition
Number
Short-Hand Summary ofAudit Policy Conditions
1
Systematic Discovery of the violation through an environmental audit or a compliance management system
2Voluntary Discovery in other words it is not through a legally required monitoring sampling or auditing procedure
3
Prompt Disclosure in writing to EPA within 21 days of discovery or any shorter time required by law
4 Independent Discovery and Disclosure
5
Correction and Remediation within 60 days in most cases from date of discovery
6 Prevent recurrence of a violation
7
Repeat violations are not eligible for mitigation under the Audit Policy
8 Certain violations are not eligible
9 Cooperation by the disclosing entity is required
Conditions of Policy
1 Systematic Discovery of the violation through an environmental audit or a compliance management system
2 Voluntary Discovery that is not through a legally required monitoring sampling or auditing procedure
Conditions of Policy cont
3 Prompt disclosure in writing to EPA within 21 days of discovery or any shorter time required by law
bull Discovery occurs when any officer director employee or agent of the facility has an objectively reasonable basis for believing that a violation has or may have occurred
Conditions of Policy cont
4 Independent discovery and disclosure before EPA likely would have identified the violation through its own investigation or based on information from a third party
5 Correction and remediation within 60 days in most cases from date of discovery
Conditions of Policy cont
6 Prevent recurrence of violation
7 Repeat violations are not eligible that is violations that occurred within the past 3 years at the same facility or as part of a pattern of violations within the past 5 years at facilities owned or operated by the same company
Conditions of Policy cont
8 Certain violations are not eligible -- those that result in serious actual harm that may have presented an imminent and substantial endangerment or that violate specific terms of an administrative or judicial order or consent agreement
9 Cooperation by the disclosing entity is required
State Self Reporting Policy
Your state may have a self reporting policy similar to the federal policy
May need to notify through both EPA and your State to receive any penalty mitigation
Things you need to do Get the inspector in amp out as quickly as
possible
Keep your records neat and orderly
Ensure records are available for review bull Location of records must be known by several
people
Audit those that transport and receive your waste (HW UW E-waste amp non-haz)
Read the Inspectorrsquos Report
SQG vs LQG Paperwork RequirementsSmall Quantity Generator
bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with
local emergency authorities
bull Emergency Info posted by a phone
bull Employees must be thoroughly familiarhellip
Large Quantity Generator
bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with
local emergency authoritiesbull Contingency Plan
bull Documented RCRA Training job descriptions
bull Biennial Reportbull Waste Min Plan (Written)
Waste minimization certification for both SQGs amp LQGs
Common Violation
Item 13 Waste Codesbull Enter up to six federalstate
waste codes to describe each waste stream identified in Item 9bndash State waste codes that are
not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste
ndash No specific required order or hierarchy for state and federal waste codes
Manifests vs LDRs
Manifests and Land Disposal Restrictions are inter-connected but separate rules
40 CFR 26220 Appendix vs 2689(b)
Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005
Manifests HW Storage Limits SQGs only
40 CFR 26234(e)Allows storage of HW for 270 days when being
transported gt 200 miles an additional 90 days
40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit
LQG 90-Day Storage Limit
40 CFR 26234(b)
Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo
Exceeding the time limit is a MAJOR violation
Hospitals
Hazardous Waste Pharmaceutical Management Standards
The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities
ndash Proposed rule anticipated publication date August 2013
Hazardous Waste Pharmaceutical Management Standards
For more information
httpwwwepagovoswhazardgenerationpharmaceuticalshtm
Waste Generated at Hospitals
Using a MSDS for Waste Determinations
OSHA regs do not require manufacturers to identify constituents present in material at concentrations below
ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)
The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS
Salts and Esters not P-listed
If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated
Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products
EPA Guidance RO12155
Epinephrine Salts
P042 listing (Epinephrine) does not apply to Epinephrine salts
Most or all Epi-pens are Epinephrine salts
EPA Guidance RO14788
Using CAS Number for Waste Determinations
Formaldehyde (CAS No 50-00-0)ndash U122 when unused
If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of
formaldehyde when disposed of amp = U122
EPA Guidance RO13658
Silver Recovery Units
Low Level Mixed Waste - LLMW
Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste
Only applies to facilities with NRC permits Notification is required if conditional
exemption is claimed Read the Rule There are conditions to to
be met
Conditions for LLMW
Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N
Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste
10 Common RCRA Violations
10
Emergency Arrangements (esp Small Quantity Generators)
Arrangements with Local Authorities
26537
The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations
SQG
LQG
Arrangements with Local Authorities(40 CFR 26537)
Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams
Layout of the facilityProperties amp associated hazards of
hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes
Arrangements with Local Authorities - Hospitals
Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the
facilityndash The types of injuries or illnesses which could result
from fires explosions or releases at the facility
9
Hazardous Waste not in Containers
8
Documentation
Common ViolationsLQG
ndash Job Descriptionsndash LQG contingency plan
Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area
LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage
area(s) documented
Job Descriptions A written job description for each position
ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position
ndash Duties describe the HW responsibilities of the individual holding that position
ndash Match name(s) to current title
Container Inspection Records
The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other
factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)
SQGLQG
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
Violations Involving the Basics
Graduate Student Labs ndash SAAs
General Services ndash UW lamps Used Oil Aerosol Cans Paint Shops Power Plants Grounds-Keeping
Contractors ndash Donrsquot rely too heavily on HW vendors Keep an eye on Construction amp Demolition Contractors
Possible Remedies When necessary find a bilingual student to
serve as the lab safety manager When making pick-ups of HW at all locations
have your staff person do a quick audit Periodically do an audit of general services ndash
donrsquot wait for pick-ups of HW Demolition ndash get your inspector to OK any
temporary SAAs or 90180 - day storage areas
Rules Announced But Not Yet Proposed
Description of rule Action Scheduled date
Improvements to the hazardous waste generator regulations
NPRM 1014
Management standards for hazardous waste pharmaceuticals
NPRM 1214
Revisions to the hazardous waste import and export requirements
NPRM 215
Revisions to LDR treatment standards and recycling requirements for spent petroleum hydrotreating and hydrorefining catalyst
NPRM DND
Revisions to the biennial report NPRM DND
Hazardous waste requirements for managing waste retail products
NPRM DND
DND = date not determined LDR = land disposal restrictions NODA = notice of data availability NPRM = notice of proposed UST = underground storage tank
Proposed Rules to Be Finalized
Description of rule Action Scheduled date
Revisions to the definition of solid waste
Final rule 0714
Revisions to secondary containment and operator training requirements for USTs
Final rule 1014
Standards for Subtitle CD management of utility coal combustion residues
Final rule 1214
UST = underground storage tank CD = construction amp demolition
RCRA Authorization
Authorized RCRA Program Not RCRA Authorization
All States except AK amp IA Alaska
Iowa
District of Columbia Puerto Rico
Guam The Virgin Islands
American Samoa
Commonwealth of the Northern Marianna Islands
Tribal Lands (unless the State specifically receives authorization for them within its borders)
RCRA Authorized StatesCan be more strict amp broad in its regulation of HW then the Federal program Examples includeAnnual hazardous waste report instead of biennial
State-specific forms for the Notification of Regulated Waste Activity (EPA 8700-12 Form)
State-specific HW Codes
Containment requirements for HW in 90-Day amp 180-Day ndash EPA requires containment for permitted facilities only
Time limits for accumulation of hazardous waste in Satellite Accumulation Areas
Where is the Academic Labs Rule in Effect
Academic Labs Rule ndash Subpart K
In 2014 86 facilities are currently operating under Subpart Kbull 56 are collegesuniversitiesbull 10 are teaching hospitals onlybull 13 are non-profit research institute onlybull 2 are collegeuniversity w a teaching hospitalbull 5 are teaching hospital and non-profit research
institute
Where is the Solvent Contaminated Wipe Rule in Effect
Summary of EPArsquosAudit Policy
Revised Policy1048708 65 FR 19617 - Effective May 11 20001048708 wwwepagovcomplianceincentivesauditingauditpolicyhtml
Incentives under Policy Penalty mitigation
No recommendation for criminal prosecution
No routine requests for audit reports
Conditions of the Audit Policy Entities that satisfy all the following conditions
are eligible for 100 penalty mitigation EPA retains its discretion to collect any economic benefit that may have been
realized as a result of non-compliance
Entities that satisfy all but the first condition -- systematic discovery -- are eligible for 75 penalty mitigation
Condition
Number
Short-Hand Summary ofAudit Policy Conditions
1
Systematic Discovery of the violation through an environmental audit or a compliance management system
2Voluntary Discovery in other words it is not through a legally required monitoring sampling or auditing procedure
3
Prompt Disclosure in writing to EPA within 21 days of discovery or any shorter time required by law
4 Independent Discovery and Disclosure
5
Correction and Remediation within 60 days in most cases from date of discovery
6 Prevent recurrence of a violation
7
Repeat violations are not eligible for mitigation under the Audit Policy
8 Certain violations are not eligible
9 Cooperation by the disclosing entity is required
Conditions of Policy
1 Systematic Discovery of the violation through an environmental audit or a compliance management system
2 Voluntary Discovery that is not through a legally required monitoring sampling or auditing procedure
Conditions of Policy cont
3 Prompt disclosure in writing to EPA within 21 days of discovery or any shorter time required by law
bull Discovery occurs when any officer director employee or agent of the facility has an objectively reasonable basis for believing that a violation has or may have occurred
Conditions of Policy cont
4 Independent discovery and disclosure before EPA likely would have identified the violation through its own investigation or based on information from a third party
5 Correction and remediation within 60 days in most cases from date of discovery
Conditions of Policy cont
6 Prevent recurrence of violation
7 Repeat violations are not eligible that is violations that occurred within the past 3 years at the same facility or as part of a pattern of violations within the past 5 years at facilities owned or operated by the same company
Conditions of Policy cont
8 Certain violations are not eligible -- those that result in serious actual harm that may have presented an imminent and substantial endangerment or that violate specific terms of an administrative or judicial order or consent agreement
9 Cooperation by the disclosing entity is required
State Self Reporting Policy
Your state may have a self reporting policy similar to the federal policy
May need to notify through both EPA and your State to receive any penalty mitigation
Things you need to do Get the inspector in amp out as quickly as
possible
Keep your records neat and orderly
Ensure records are available for review bull Location of records must be known by several
people
Audit those that transport and receive your waste (HW UW E-waste amp non-haz)
Read the Inspectorrsquos Report
SQG vs LQG Paperwork RequirementsSmall Quantity Generator
bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with
local emergency authorities
bull Emergency Info posted by a phone
bull Employees must be thoroughly familiarhellip
Large Quantity Generator
bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with
local emergency authoritiesbull Contingency Plan
bull Documented RCRA Training job descriptions
bull Biennial Reportbull Waste Min Plan (Written)
Waste minimization certification for both SQGs amp LQGs
Common Violation
Item 13 Waste Codesbull Enter up to six federalstate
waste codes to describe each waste stream identified in Item 9bndash State waste codes that are
not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste
ndash No specific required order or hierarchy for state and federal waste codes
Manifests vs LDRs
Manifests and Land Disposal Restrictions are inter-connected but separate rules
40 CFR 26220 Appendix vs 2689(b)
Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005
Manifests HW Storage Limits SQGs only
40 CFR 26234(e)Allows storage of HW for 270 days when being
transported gt 200 miles an additional 90 days
40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit
LQG 90-Day Storage Limit
40 CFR 26234(b)
Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo
Exceeding the time limit is a MAJOR violation
Hospitals
Hazardous Waste Pharmaceutical Management Standards
The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities
ndash Proposed rule anticipated publication date August 2013
Hazardous Waste Pharmaceutical Management Standards
For more information
httpwwwepagovoswhazardgenerationpharmaceuticalshtm
Waste Generated at Hospitals
Using a MSDS for Waste Determinations
OSHA regs do not require manufacturers to identify constituents present in material at concentrations below
ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)
The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS
Salts and Esters not P-listed
If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated
Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products
EPA Guidance RO12155
Epinephrine Salts
P042 listing (Epinephrine) does not apply to Epinephrine salts
Most or all Epi-pens are Epinephrine salts
EPA Guidance RO14788
Using CAS Number for Waste Determinations
Formaldehyde (CAS No 50-00-0)ndash U122 when unused
If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of
formaldehyde when disposed of amp = U122
EPA Guidance RO13658
Silver Recovery Units
Low Level Mixed Waste - LLMW
Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste
Only applies to facilities with NRC permits Notification is required if conditional
exemption is claimed Read the Rule There are conditions to to
be met
Conditions for LLMW
Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N
Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste
10 Common RCRA Violations
10
Emergency Arrangements (esp Small Quantity Generators)
Arrangements with Local Authorities
26537
The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations
SQG
LQG
Arrangements with Local Authorities(40 CFR 26537)
Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams
Layout of the facilityProperties amp associated hazards of
hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes
Arrangements with Local Authorities - Hospitals
Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the
facilityndash The types of injuries or illnesses which could result
from fires explosions or releases at the facility
9
Hazardous Waste not in Containers
8
Documentation
Common ViolationsLQG
ndash Job Descriptionsndash LQG contingency plan
Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area
LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage
area(s) documented
Job Descriptions A written job description for each position
ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position
ndash Duties describe the HW responsibilities of the individual holding that position
ndash Match name(s) to current title
Container Inspection Records
The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other
factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)
SQGLQG
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
Possible Remedies When necessary find a bilingual student to
serve as the lab safety manager When making pick-ups of HW at all locations
have your staff person do a quick audit Periodically do an audit of general services ndash
donrsquot wait for pick-ups of HW Demolition ndash get your inspector to OK any
temporary SAAs or 90180 - day storage areas
Rules Announced But Not Yet Proposed
Description of rule Action Scheduled date
Improvements to the hazardous waste generator regulations
NPRM 1014
Management standards for hazardous waste pharmaceuticals
NPRM 1214
Revisions to the hazardous waste import and export requirements
NPRM 215
Revisions to LDR treatment standards and recycling requirements for spent petroleum hydrotreating and hydrorefining catalyst
NPRM DND
Revisions to the biennial report NPRM DND
Hazardous waste requirements for managing waste retail products
NPRM DND
DND = date not determined LDR = land disposal restrictions NODA = notice of data availability NPRM = notice of proposed UST = underground storage tank
Proposed Rules to Be Finalized
Description of rule Action Scheduled date
Revisions to the definition of solid waste
Final rule 0714
Revisions to secondary containment and operator training requirements for USTs
Final rule 1014
Standards for Subtitle CD management of utility coal combustion residues
Final rule 1214
UST = underground storage tank CD = construction amp demolition
RCRA Authorization
Authorized RCRA Program Not RCRA Authorization
All States except AK amp IA Alaska
Iowa
District of Columbia Puerto Rico
Guam The Virgin Islands
American Samoa
Commonwealth of the Northern Marianna Islands
Tribal Lands (unless the State specifically receives authorization for them within its borders)
RCRA Authorized StatesCan be more strict amp broad in its regulation of HW then the Federal program Examples includeAnnual hazardous waste report instead of biennial
State-specific forms for the Notification of Regulated Waste Activity (EPA 8700-12 Form)
State-specific HW Codes
Containment requirements for HW in 90-Day amp 180-Day ndash EPA requires containment for permitted facilities only
Time limits for accumulation of hazardous waste in Satellite Accumulation Areas
Where is the Academic Labs Rule in Effect
Academic Labs Rule ndash Subpart K
In 2014 86 facilities are currently operating under Subpart Kbull 56 are collegesuniversitiesbull 10 are teaching hospitals onlybull 13 are non-profit research institute onlybull 2 are collegeuniversity w a teaching hospitalbull 5 are teaching hospital and non-profit research
institute
Where is the Solvent Contaminated Wipe Rule in Effect
Summary of EPArsquosAudit Policy
Revised Policy1048708 65 FR 19617 - Effective May 11 20001048708 wwwepagovcomplianceincentivesauditingauditpolicyhtml
Incentives under Policy Penalty mitigation
No recommendation for criminal prosecution
No routine requests for audit reports
Conditions of the Audit Policy Entities that satisfy all the following conditions
are eligible for 100 penalty mitigation EPA retains its discretion to collect any economic benefit that may have been
realized as a result of non-compliance
Entities that satisfy all but the first condition -- systematic discovery -- are eligible for 75 penalty mitigation
Condition
Number
Short-Hand Summary ofAudit Policy Conditions
1
Systematic Discovery of the violation through an environmental audit or a compliance management system
2Voluntary Discovery in other words it is not through a legally required monitoring sampling or auditing procedure
3
Prompt Disclosure in writing to EPA within 21 days of discovery or any shorter time required by law
4 Independent Discovery and Disclosure
5
Correction and Remediation within 60 days in most cases from date of discovery
6 Prevent recurrence of a violation
7
Repeat violations are not eligible for mitigation under the Audit Policy
8 Certain violations are not eligible
9 Cooperation by the disclosing entity is required
Conditions of Policy
1 Systematic Discovery of the violation through an environmental audit or a compliance management system
2 Voluntary Discovery that is not through a legally required monitoring sampling or auditing procedure
Conditions of Policy cont
3 Prompt disclosure in writing to EPA within 21 days of discovery or any shorter time required by law
bull Discovery occurs when any officer director employee or agent of the facility has an objectively reasonable basis for believing that a violation has or may have occurred
Conditions of Policy cont
4 Independent discovery and disclosure before EPA likely would have identified the violation through its own investigation or based on information from a third party
5 Correction and remediation within 60 days in most cases from date of discovery
Conditions of Policy cont
6 Prevent recurrence of violation
7 Repeat violations are not eligible that is violations that occurred within the past 3 years at the same facility or as part of a pattern of violations within the past 5 years at facilities owned or operated by the same company
Conditions of Policy cont
8 Certain violations are not eligible -- those that result in serious actual harm that may have presented an imminent and substantial endangerment or that violate specific terms of an administrative or judicial order or consent agreement
9 Cooperation by the disclosing entity is required
State Self Reporting Policy
Your state may have a self reporting policy similar to the federal policy
May need to notify through both EPA and your State to receive any penalty mitigation
Things you need to do Get the inspector in amp out as quickly as
possible
Keep your records neat and orderly
Ensure records are available for review bull Location of records must be known by several
people
Audit those that transport and receive your waste (HW UW E-waste amp non-haz)
Read the Inspectorrsquos Report
SQG vs LQG Paperwork RequirementsSmall Quantity Generator
bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with
local emergency authorities
bull Emergency Info posted by a phone
bull Employees must be thoroughly familiarhellip
Large Quantity Generator
bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with
local emergency authoritiesbull Contingency Plan
bull Documented RCRA Training job descriptions
bull Biennial Reportbull Waste Min Plan (Written)
Waste minimization certification for both SQGs amp LQGs
Common Violation
Item 13 Waste Codesbull Enter up to six federalstate
waste codes to describe each waste stream identified in Item 9bndash State waste codes that are
not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste
ndash No specific required order or hierarchy for state and federal waste codes
Manifests vs LDRs
Manifests and Land Disposal Restrictions are inter-connected but separate rules
40 CFR 26220 Appendix vs 2689(b)
Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005
Manifests HW Storage Limits SQGs only
40 CFR 26234(e)Allows storage of HW for 270 days when being
transported gt 200 miles an additional 90 days
40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit
LQG 90-Day Storage Limit
40 CFR 26234(b)
Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo
Exceeding the time limit is a MAJOR violation
Hospitals
Hazardous Waste Pharmaceutical Management Standards
The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities
ndash Proposed rule anticipated publication date August 2013
Hazardous Waste Pharmaceutical Management Standards
For more information
httpwwwepagovoswhazardgenerationpharmaceuticalshtm
Waste Generated at Hospitals
Using a MSDS for Waste Determinations
OSHA regs do not require manufacturers to identify constituents present in material at concentrations below
ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)
The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS
Salts and Esters not P-listed
If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated
Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products
EPA Guidance RO12155
Epinephrine Salts
P042 listing (Epinephrine) does not apply to Epinephrine salts
Most or all Epi-pens are Epinephrine salts
EPA Guidance RO14788
Using CAS Number for Waste Determinations
Formaldehyde (CAS No 50-00-0)ndash U122 when unused
If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of
formaldehyde when disposed of amp = U122
EPA Guidance RO13658
Silver Recovery Units
Low Level Mixed Waste - LLMW
Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste
Only applies to facilities with NRC permits Notification is required if conditional
exemption is claimed Read the Rule There are conditions to to
be met
Conditions for LLMW
Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N
Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste
10 Common RCRA Violations
10
Emergency Arrangements (esp Small Quantity Generators)
Arrangements with Local Authorities
26537
The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations
SQG
LQG
Arrangements with Local Authorities(40 CFR 26537)
Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams
Layout of the facilityProperties amp associated hazards of
hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes
Arrangements with Local Authorities - Hospitals
Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the
facilityndash The types of injuries or illnesses which could result
from fires explosions or releases at the facility
9
Hazardous Waste not in Containers
8
Documentation
Common ViolationsLQG
ndash Job Descriptionsndash LQG contingency plan
Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area
LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage
area(s) documented
Job Descriptions A written job description for each position
ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position
ndash Duties describe the HW responsibilities of the individual holding that position
ndash Match name(s) to current title
Container Inspection Records
The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other
factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)
SQGLQG
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
Rules Announced But Not Yet Proposed
Description of rule Action Scheduled date
Improvements to the hazardous waste generator regulations
NPRM 1014
Management standards for hazardous waste pharmaceuticals
NPRM 1214
Revisions to the hazardous waste import and export requirements
NPRM 215
Revisions to LDR treatment standards and recycling requirements for spent petroleum hydrotreating and hydrorefining catalyst
NPRM DND
Revisions to the biennial report NPRM DND
Hazardous waste requirements for managing waste retail products
NPRM DND
DND = date not determined LDR = land disposal restrictions NODA = notice of data availability NPRM = notice of proposed UST = underground storage tank
Proposed Rules to Be Finalized
Description of rule Action Scheduled date
Revisions to the definition of solid waste
Final rule 0714
Revisions to secondary containment and operator training requirements for USTs
Final rule 1014
Standards for Subtitle CD management of utility coal combustion residues
Final rule 1214
UST = underground storage tank CD = construction amp demolition
RCRA Authorization
Authorized RCRA Program Not RCRA Authorization
All States except AK amp IA Alaska
Iowa
District of Columbia Puerto Rico
Guam The Virgin Islands
American Samoa
Commonwealth of the Northern Marianna Islands
Tribal Lands (unless the State specifically receives authorization for them within its borders)
RCRA Authorized StatesCan be more strict amp broad in its regulation of HW then the Federal program Examples includeAnnual hazardous waste report instead of biennial
State-specific forms for the Notification of Regulated Waste Activity (EPA 8700-12 Form)
State-specific HW Codes
Containment requirements for HW in 90-Day amp 180-Day ndash EPA requires containment for permitted facilities only
Time limits for accumulation of hazardous waste in Satellite Accumulation Areas
Where is the Academic Labs Rule in Effect
Academic Labs Rule ndash Subpart K
In 2014 86 facilities are currently operating under Subpart Kbull 56 are collegesuniversitiesbull 10 are teaching hospitals onlybull 13 are non-profit research institute onlybull 2 are collegeuniversity w a teaching hospitalbull 5 are teaching hospital and non-profit research
institute
Where is the Solvent Contaminated Wipe Rule in Effect
Summary of EPArsquosAudit Policy
Revised Policy1048708 65 FR 19617 - Effective May 11 20001048708 wwwepagovcomplianceincentivesauditingauditpolicyhtml
Incentives under Policy Penalty mitigation
No recommendation for criminal prosecution
No routine requests for audit reports
Conditions of the Audit Policy Entities that satisfy all the following conditions
are eligible for 100 penalty mitigation EPA retains its discretion to collect any economic benefit that may have been
realized as a result of non-compliance
Entities that satisfy all but the first condition -- systematic discovery -- are eligible for 75 penalty mitigation
Condition
Number
Short-Hand Summary ofAudit Policy Conditions
1
Systematic Discovery of the violation through an environmental audit or a compliance management system
2Voluntary Discovery in other words it is not through a legally required monitoring sampling or auditing procedure
3
Prompt Disclosure in writing to EPA within 21 days of discovery or any shorter time required by law
4 Independent Discovery and Disclosure
5
Correction and Remediation within 60 days in most cases from date of discovery
6 Prevent recurrence of a violation
7
Repeat violations are not eligible for mitigation under the Audit Policy
8 Certain violations are not eligible
9 Cooperation by the disclosing entity is required
Conditions of Policy
1 Systematic Discovery of the violation through an environmental audit or a compliance management system
2 Voluntary Discovery that is not through a legally required monitoring sampling or auditing procedure
Conditions of Policy cont
3 Prompt disclosure in writing to EPA within 21 days of discovery or any shorter time required by law
bull Discovery occurs when any officer director employee or agent of the facility has an objectively reasonable basis for believing that a violation has or may have occurred
Conditions of Policy cont
4 Independent discovery and disclosure before EPA likely would have identified the violation through its own investigation or based on information from a third party
5 Correction and remediation within 60 days in most cases from date of discovery
Conditions of Policy cont
6 Prevent recurrence of violation
7 Repeat violations are not eligible that is violations that occurred within the past 3 years at the same facility or as part of a pattern of violations within the past 5 years at facilities owned or operated by the same company
Conditions of Policy cont
8 Certain violations are not eligible -- those that result in serious actual harm that may have presented an imminent and substantial endangerment or that violate specific terms of an administrative or judicial order or consent agreement
9 Cooperation by the disclosing entity is required
State Self Reporting Policy
Your state may have a self reporting policy similar to the federal policy
May need to notify through both EPA and your State to receive any penalty mitigation
Things you need to do Get the inspector in amp out as quickly as
possible
Keep your records neat and orderly
Ensure records are available for review bull Location of records must be known by several
people
Audit those that transport and receive your waste (HW UW E-waste amp non-haz)
Read the Inspectorrsquos Report
SQG vs LQG Paperwork RequirementsSmall Quantity Generator
bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with
local emergency authorities
bull Emergency Info posted by a phone
bull Employees must be thoroughly familiarhellip
Large Quantity Generator
bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with
local emergency authoritiesbull Contingency Plan
bull Documented RCRA Training job descriptions
bull Biennial Reportbull Waste Min Plan (Written)
Waste minimization certification for both SQGs amp LQGs
Common Violation
Item 13 Waste Codesbull Enter up to six federalstate
waste codes to describe each waste stream identified in Item 9bndash State waste codes that are
not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste
ndash No specific required order or hierarchy for state and federal waste codes
Manifests vs LDRs
Manifests and Land Disposal Restrictions are inter-connected but separate rules
40 CFR 26220 Appendix vs 2689(b)
Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005
Manifests HW Storage Limits SQGs only
40 CFR 26234(e)Allows storage of HW for 270 days when being
transported gt 200 miles an additional 90 days
40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit
LQG 90-Day Storage Limit
40 CFR 26234(b)
Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo
Exceeding the time limit is a MAJOR violation
Hospitals
Hazardous Waste Pharmaceutical Management Standards
The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities
ndash Proposed rule anticipated publication date August 2013
Hazardous Waste Pharmaceutical Management Standards
For more information
httpwwwepagovoswhazardgenerationpharmaceuticalshtm
Waste Generated at Hospitals
Using a MSDS for Waste Determinations
OSHA regs do not require manufacturers to identify constituents present in material at concentrations below
ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)
The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS
Salts and Esters not P-listed
If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated
Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products
EPA Guidance RO12155
Epinephrine Salts
P042 listing (Epinephrine) does not apply to Epinephrine salts
Most or all Epi-pens are Epinephrine salts
EPA Guidance RO14788
Using CAS Number for Waste Determinations
Formaldehyde (CAS No 50-00-0)ndash U122 when unused
If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of
formaldehyde when disposed of amp = U122
EPA Guidance RO13658
Silver Recovery Units
Low Level Mixed Waste - LLMW
Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste
Only applies to facilities with NRC permits Notification is required if conditional
exemption is claimed Read the Rule There are conditions to to
be met
Conditions for LLMW
Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N
Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste
10 Common RCRA Violations
10
Emergency Arrangements (esp Small Quantity Generators)
Arrangements with Local Authorities
26537
The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations
SQG
LQG
Arrangements with Local Authorities(40 CFR 26537)
Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams
Layout of the facilityProperties amp associated hazards of
hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes
Arrangements with Local Authorities - Hospitals
Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the
facilityndash The types of injuries or illnesses which could result
from fires explosions or releases at the facility
9
Hazardous Waste not in Containers
8
Documentation
Common ViolationsLQG
ndash Job Descriptionsndash LQG contingency plan
Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area
LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage
area(s) documented
Job Descriptions A written job description for each position
ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position
ndash Duties describe the HW responsibilities of the individual holding that position
ndash Match name(s) to current title
Container Inspection Records
The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other
factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)
SQGLQG
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
Proposed Rules to Be Finalized
Description of rule Action Scheduled date
Revisions to the definition of solid waste
Final rule 0714
Revisions to secondary containment and operator training requirements for USTs
Final rule 1014
Standards for Subtitle CD management of utility coal combustion residues
Final rule 1214
UST = underground storage tank CD = construction amp demolition
RCRA Authorization
Authorized RCRA Program Not RCRA Authorization
All States except AK amp IA Alaska
Iowa
District of Columbia Puerto Rico
Guam The Virgin Islands
American Samoa
Commonwealth of the Northern Marianna Islands
Tribal Lands (unless the State specifically receives authorization for them within its borders)
RCRA Authorized StatesCan be more strict amp broad in its regulation of HW then the Federal program Examples includeAnnual hazardous waste report instead of biennial
State-specific forms for the Notification of Regulated Waste Activity (EPA 8700-12 Form)
State-specific HW Codes
Containment requirements for HW in 90-Day amp 180-Day ndash EPA requires containment for permitted facilities only
Time limits for accumulation of hazardous waste in Satellite Accumulation Areas
Where is the Academic Labs Rule in Effect
Academic Labs Rule ndash Subpart K
In 2014 86 facilities are currently operating under Subpart Kbull 56 are collegesuniversitiesbull 10 are teaching hospitals onlybull 13 are non-profit research institute onlybull 2 are collegeuniversity w a teaching hospitalbull 5 are teaching hospital and non-profit research
institute
Where is the Solvent Contaminated Wipe Rule in Effect
Summary of EPArsquosAudit Policy
Revised Policy1048708 65 FR 19617 - Effective May 11 20001048708 wwwepagovcomplianceincentivesauditingauditpolicyhtml
Incentives under Policy Penalty mitigation
No recommendation for criminal prosecution
No routine requests for audit reports
Conditions of the Audit Policy Entities that satisfy all the following conditions
are eligible for 100 penalty mitigation EPA retains its discretion to collect any economic benefit that may have been
realized as a result of non-compliance
Entities that satisfy all but the first condition -- systematic discovery -- are eligible for 75 penalty mitigation
Condition
Number
Short-Hand Summary ofAudit Policy Conditions
1
Systematic Discovery of the violation through an environmental audit or a compliance management system
2Voluntary Discovery in other words it is not through a legally required monitoring sampling or auditing procedure
3
Prompt Disclosure in writing to EPA within 21 days of discovery or any shorter time required by law
4 Independent Discovery and Disclosure
5
Correction and Remediation within 60 days in most cases from date of discovery
6 Prevent recurrence of a violation
7
Repeat violations are not eligible for mitigation under the Audit Policy
8 Certain violations are not eligible
9 Cooperation by the disclosing entity is required
Conditions of Policy
1 Systematic Discovery of the violation through an environmental audit or a compliance management system
2 Voluntary Discovery that is not through a legally required monitoring sampling or auditing procedure
Conditions of Policy cont
3 Prompt disclosure in writing to EPA within 21 days of discovery or any shorter time required by law
bull Discovery occurs when any officer director employee or agent of the facility has an objectively reasonable basis for believing that a violation has or may have occurred
Conditions of Policy cont
4 Independent discovery and disclosure before EPA likely would have identified the violation through its own investigation or based on information from a third party
5 Correction and remediation within 60 days in most cases from date of discovery
Conditions of Policy cont
6 Prevent recurrence of violation
7 Repeat violations are not eligible that is violations that occurred within the past 3 years at the same facility or as part of a pattern of violations within the past 5 years at facilities owned or operated by the same company
Conditions of Policy cont
8 Certain violations are not eligible -- those that result in serious actual harm that may have presented an imminent and substantial endangerment or that violate specific terms of an administrative or judicial order or consent agreement
9 Cooperation by the disclosing entity is required
State Self Reporting Policy
Your state may have a self reporting policy similar to the federal policy
May need to notify through both EPA and your State to receive any penalty mitigation
Things you need to do Get the inspector in amp out as quickly as
possible
Keep your records neat and orderly
Ensure records are available for review bull Location of records must be known by several
people
Audit those that transport and receive your waste (HW UW E-waste amp non-haz)
Read the Inspectorrsquos Report
SQG vs LQG Paperwork RequirementsSmall Quantity Generator
bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with
local emergency authorities
bull Emergency Info posted by a phone
bull Employees must be thoroughly familiarhellip
Large Quantity Generator
bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with
local emergency authoritiesbull Contingency Plan
bull Documented RCRA Training job descriptions
bull Biennial Reportbull Waste Min Plan (Written)
Waste minimization certification for both SQGs amp LQGs
Common Violation
Item 13 Waste Codesbull Enter up to six federalstate
waste codes to describe each waste stream identified in Item 9bndash State waste codes that are
not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste
ndash No specific required order or hierarchy for state and federal waste codes
Manifests vs LDRs
Manifests and Land Disposal Restrictions are inter-connected but separate rules
40 CFR 26220 Appendix vs 2689(b)
Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005
Manifests HW Storage Limits SQGs only
40 CFR 26234(e)Allows storage of HW for 270 days when being
transported gt 200 miles an additional 90 days
40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit
LQG 90-Day Storage Limit
40 CFR 26234(b)
Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo
Exceeding the time limit is a MAJOR violation
Hospitals
Hazardous Waste Pharmaceutical Management Standards
The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities
ndash Proposed rule anticipated publication date August 2013
Hazardous Waste Pharmaceutical Management Standards
For more information
httpwwwepagovoswhazardgenerationpharmaceuticalshtm
Waste Generated at Hospitals
Using a MSDS for Waste Determinations
OSHA regs do not require manufacturers to identify constituents present in material at concentrations below
ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)
The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS
Salts and Esters not P-listed
If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated
Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products
EPA Guidance RO12155
Epinephrine Salts
P042 listing (Epinephrine) does not apply to Epinephrine salts
Most or all Epi-pens are Epinephrine salts
EPA Guidance RO14788
Using CAS Number for Waste Determinations
Formaldehyde (CAS No 50-00-0)ndash U122 when unused
If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of
formaldehyde when disposed of amp = U122
EPA Guidance RO13658
Silver Recovery Units
Low Level Mixed Waste - LLMW
Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste
Only applies to facilities with NRC permits Notification is required if conditional
exemption is claimed Read the Rule There are conditions to to
be met
Conditions for LLMW
Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N
Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste
10 Common RCRA Violations
10
Emergency Arrangements (esp Small Quantity Generators)
Arrangements with Local Authorities
26537
The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations
SQG
LQG
Arrangements with Local Authorities(40 CFR 26537)
Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams
Layout of the facilityProperties amp associated hazards of
hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes
Arrangements with Local Authorities - Hospitals
Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the
facilityndash The types of injuries or illnesses which could result
from fires explosions or releases at the facility
9
Hazardous Waste not in Containers
8
Documentation
Common ViolationsLQG
ndash Job Descriptionsndash LQG contingency plan
Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area
LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage
area(s) documented
Job Descriptions A written job description for each position
ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position
ndash Duties describe the HW responsibilities of the individual holding that position
ndash Match name(s) to current title
Container Inspection Records
The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other
factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)
SQGLQG
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
RCRA Authorization
Authorized RCRA Program Not RCRA Authorization
All States except AK amp IA Alaska
Iowa
District of Columbia Puerto Rico
Guam The Virgin Islands
American Samoa
Commonwealth of the Northern Marianna Islands
Tribal Lands (unless the State specifically receives authorization for them within its borders)
RCRA Authorized StatesCan be more strict amp broad in its regulation of HW then the Federal program Examples includeAnnual hazardous waste report instead of biennial
State-specific forms for the Notification of Regulated Waste Activity (EPA 8700-12 Form)
State-specific HW Codes
Containment requirements for HW in 90-Day amp 180-Day ndash EPA requires containment for permitted facilities only
Time limits for accumulation of hazardous waste in Satellite Accumulation Areas
Where is the Academic Labs Rule in Effect
Academic Labs Rule ndash Subpart K
In 2014 86 facilities are currently operating under Subpart Kbull 56 are collegesuniversitiesbull 10 are teaching hospitals onlybull 13 are non-profit research institute onlybull 2 are collegeuniversity w a teaching hospitalbull 5 are teaching hospital and non-profit research
institute
Where is the Solvent Contaminated Wipe Rule in Effect
Summary of EPArsquosAudit Policy
Revised Policy1048708 65 FR 19617 - Effective May 11 20001048708 wwwepagovcomplianceincentivesauditingauditpolicyhtml
Incentives under Policy Penalty mitigation
No recommendation for criminal prosecution
No routine requests for audit reports
Conditions of the Audit Policy Entities that satisfy all the following conditions
are eligible for 100 penalty mitigation EPA retains its discretion to collect any economic benefit that may have been
realized as a result of non-compliance
Entities that satisfy all but the first condition -- systematic discovery -- are eligible for 75 penalty mitigation
Condition
Number
Short-Hand Summary ofAudit Policy Conditions
1
Systematic Discovery of the violation through an environmental audit or a compliance management system
2Voluntary Discovery in other words it is not through a legally required monitoring sampling or auditing procedure
3
Prompt Disclosure in writing to EPA within 21 days of discovery or any shorter time required by law
4 Independent Discovery and Disclosure
5
Correction and Remediation within 60 days in most cases from date of discovery
6 Prevent recurrence of a violation
7
Repeat violations are not eligible for mitigation under the Audit Policy
8 Certain violations are not eligible
9 Cooperation by the disclosing entity is required
Conditions of Policy
1 Systematic Discovery of the violation through an environmental audit or a compliance management system
2 Voluntary Discovery that is not through a legally required monitoring sampling or auditing procedure
Conditions of Policy cont
3 Prompt disclosure in writing to EPA within 21 days of discovery or any shorter time required by law
bull Discovery occurs when any officer director employee or agent of the facility has an objectively reasonable basis for believing that a violation has or may have occurred
Conditions of Policy cont
4 Independent discovery and disclosure before EPA likely would have identified the violation through its own investigation or based on information from a third party
5 Correction and remediation within 60 days in most cases from date of discovery
Conditions of Policy cont
6 Prevent recurrence of violation
7 Repeat violations are not eligible that is violations that occurred within the past 3 years at the same facility or as part of a pattern of violations within the past 5 years at facilities owned or operated by the same company
Conditions of Policy cont
8 Certain violations are not eligible -- those that result in serious actual harm that may have presented an imminent and substantial endangerment or that violate specific terms of an administrative or judicial order or consent agreement
9 Cooperation by the disclosing entity is required
State Self Reporting Policy
Your state may have a self reporting policy similar to the federal policy
May need to notify through both EPA and your State to receive any penalty mitigation
Things you need to do Get the inspector in amp out as quickly as
possible
Keep your records neat and orderly
Ensure records are available for review bull Location of records must be known by several
people
Audit those that transport and receive your waste (HW UW E-waste amp non-haz)
Read the Inspectorrsquos Report
SQG vs LQG Paperwork RequirementsSmall Quantity Generator
bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with
local emergency authorities
bull Emergency Info posted by a phone
bull Employees must be thoroughly familiarhellip
Large Quantity Generator
bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with
local emergency authoritiesbull Contingency Plan
bull Documented RCRA Training job descriptions
bull Biennial Reportbull Waste Min Plan (Written)
Waste minimization certification for both SQGs amp LQGs
Common Violation
Item 13 Waste Codesbull Enter up to six federalstate
waste codes to describe each waste stream identified in Item 9bndash State waste codes that are
not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste
ndash No specific required order or hierarchy for state and federal waste codes
Manifests vs LDRs
Manifests and Land Disposal Restrictions are inter-connected but separate rules
40 CFR 26220 Appendix vs 2689(b)
Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005
Manifests HW Storage Limits SQGs only
40 CFR 26234(e)Allows storage of HW for 270 days when being
transported gt 200 miles an additional 90 days
40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit
LQG 90-Day Storage Limit
40 CFR 26234(b)
Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo
Exceeding the time limit is a MAJOR violation
Hospitals
Hazardous Waste Pharmaceutical Management Standards
The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities
ndash Proposed rule anticipated publication date August 2013
Hazardous Waste Pharmaceutical Management Standards
For more information
httpwwwepagovoswhazardgenerationpharmaceuticalshtm
Waste Generated at Hospitals
Using a MSDS for Waste Determinations
OSHA regs do not require manufacturers to identify constituents present in material at concentrations below
ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)
The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS
Salts and Esters not P-listed
If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated
Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products
EPA Guidance RO12155
Epinephrine Salts
P042 listing (Epinephrine) does not apply to Epinephrine salts
Most or all Epi-pens are Epinephrine salts
EPA Guidance RO14788
Using CAS Number for Waste Determinations
Formaldehyde (CAS No 50-00-0)ndash U122 when unused
If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of
formaldehyde when disposed of amp = U122
EPA Guidance RO13658
Silver Recovery Units
Low Level Mixed Waste - LLMW
Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste
Only applies to facilities with NRC permits Notification is required if conditional
exemption is claimed Read the Rule There are conditions to to
be met
Conditions for LLMW
Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N
Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste
10 Common RCRA Violations
10
Emergency Arrangements (esp Small Quantity Generators)
Arrangements with Local Authorities
26537
The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations
SQG
LQG
Arrangements with Local Authorities(40 CFR 26537)
Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams
Layout of the facilityProperties amp associated hazards of
hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes
Arrangements with Local Authorities - Hospitals
Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the
facilityndash The types of injuries or illnesses which could result
from fires explosions or releases at the facility
9
Hazardous Waste not in Containers
8
Documentation
Common ViolationsLQG
ndash Job Descriptionsndash LQG contingency plan
Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area
LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage
area(s) documented
Job Descriptions A written job description for each position
ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position
ndash Duties describe the HW responsibilities of the individual holding that position
ndash Match name(s) to current title
Container Inspection Records
The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other
factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)
SQGLQG
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
RCRA Authorized StatesCan be more strict amp broad in its regulation of HW then the Federal program Examples includeAnnual hazardous waste report instead of biennial
State-specific forms for the Notification of Regulated Waste Activity (EPA 8700-12 Form)
State-specific HW Codes
Containment requirements for HW in 90-Day amp 180-Day ndash EPA requires containment for permitted facilities only
Time limits for accumulation of hazardous waste in Satellite Accumulation Areas
Where is the Academic Labs Rule in Effect
Academic Labs Rule ndash Subpart K
In 2014 86 facilities are currently operating under Subpart Kbull 56 are collegesuniversitiesbull 10 are teaching hospitals onlybull 13 are non-profit research institute onlybull 2 are collegeuniversity w a teaching hospitalbull 5 are teaching hospital and non-profit research
institute
Where is the Solvent Contaminated Wipe Rule in Effect
Summary of EPArsquosAudit Policy
Revised Policy1048708 65 FR 19617 - Effective May 11 20001048708 wwwepagovcomplianceincentivesauditingauditpolicyhtml
Incentives under Policy Penalty mitigation
No recommendation for criminal prosecution
No routine requests for audit reports
Conditions of the Audit Policy Entities that satisfy all the following conditions
are eligible for 100 penalty mitigation EPA retains its discretion to collect any economic benefit that may have been
realized as a result of non-compliance
Entities that satisfy all but the first condition -- systematic discovery -- are eligible for 75 penalty mitigation
Condition
Number
Short-Hand Summary ofAudit Policy Conditions
1
Systematic Discovery of the violation through an environmental audit or a compliance management system
2Voluntary Discovery in other words it is not through a legally required monitoring sampling or auditing procedure
3
Prompt Disclosure in writing to EPA within 21 days of discovery or any shorter time required by law
4 Independent Discovery and Disclosure
5
Correction and Remediation within 60 days in most cases from date of discovery
6 Prevent recurrence of a violation
7
Repeat violations are not eligible for mitigation under the Audit Policy
8 Certain violations are not eligible
9 Cooperation by the disclosing entity is required
Conditions of Policy
1 Systematic Discovery of the violation through an environmental audit or a compliance management system
2 Voluntary Discovery that is not through a legally required monitoring sampling or auditing procedure
Conditions of Policy cont
3 Prompt disclosure in writing to EPA within 21 days of discovery or any shorter time required by law
bull Discovery occurs when any officer director employee or agent of the facility has an objectively reasonable basis for believing that a violation has or may have occurred
Conditions of Policy cont
4 Independent discovery and disclosure before EPA likely would have identified the violation through its own investigation or based on information from a third party
5 Correction and remediation within 60 days in most cases from date of discovery
Conditions of Policy cont
6 Prevent recurrence of violation
7 Repeat violations are not eligible that is violations that occurred within the past 3 years at the same facility or as part of a pattern of violations within the past 5 years at facilities owned or operated by the same company
Conditions of Policy cont
8 Certain violations are not eligible -- those that result in serious actual harm that may have presented an imminent and substantial endangerment or that violate specific terms of an administrative or judicial order or consent agreement
9 Cooperation by the disclosing entity is required
State Self Reporting Policy
Your state may have a self reporting policy similar to the federal policy
May need to notify through both EPA and your State to receive any penalty mitigation
Things you need to do Get the inspector in amp out as quickly as
possible
Keep your records neat and orderly
Ensure records are available for review bull Location of records must be known by several
people
Audit those that transport and receive your waste (HW UW E-waste amp non-haz)
Read the Inspectorrsquos Report
SQG vs LQG Paperwork RequirementsSmall Quantity Generator
bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with
local emergency authorities
bull Emergency Info posted by a phone
bull Employees must be thoroughly familiarhellip
Large Quantity Generator
bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with
local emergency authoritiesbull Contingency Plan
bull Documented RCRA Training job descriptions
bull Biennial Reportbull Waste Min Plan (Written)
Waste minimization certification for both SQGs amp LQGs
Common Violation
Item 13 Waste Codesbull Enter up to six federalstate
waste codes to describe each waste stream identified in Item 9bndash State waste codes that are
not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste
ndash No specific required order or hierarchy for state and federal waste codes
Manifests vs LDRs
Manifests and Land Disposal Restrictions are inter-connected but separate rules
40 CFR 26220 Appendix vs 2689(b)
Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005
Manifests HW Storage Limits SQGs only
40 CFR 26234(e)Allows storage of HW for 270 days when being
transported gt 200 miles an additional 90 days
40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit
LQG 90-Day Storage Limit
40 CFR 26234(b)
Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo
Exceeding the time limit is a MAJOR violation
Hospitals
Hazardous Waste Pharmaceutical Management Standards
The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities
ndash Proposed rule anticipated publication date August 2013
Hazardous Waste Pharmaceutical Management Standards
For more information
httpwwwepagovoswhazardgenerationpharmaceuticalshtm
Waste Generated at Hospitals
Using a MSDS for Waste Determinations
OSHA regs do not require manufacturers to identify constituents present in material at concentrations below
ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)
The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS
Salts and Esters not P-listed
If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated
Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products
EPA Guidance RO12155
Epinephrine Salts
P042 listing (Epinephrine) does not apply to Epinephrine salts
Most or all Epi-pens are Epinephrine salts
EPA Guidance RO14788
Using CAS Number for Waste Determinations
Formaldehyde (CAS No 50-00-0)ndash U122 when unused
If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of
formaldehyde when disposed of amp = U122
EPA Guidance RO13658
Silver Recovery Units
Low Level Mixed Waste - LLMW
Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste
Only applies to facilities with NRC permits Notification is required if conditional
exemption is claimed Read the Rule There are conditions to to
be met
Conditions for LLMW
Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N
Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste
10 Common RCRA Violations
10
Emergency Arrangements (esp Small Quantity Generators)
Arrangements with Local Authorities
26537
The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations
SQG
LQG
Arrangements with Local Authorities(40 CFR 26537)
Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams
Layout of the facilityProperties amp associated hazards of
hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes
Arrangements with Local Authorities - Hospitals
Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the
facilityndash The types of injuries or illnesses which could result
from fires explosions or releases at the facility
9
Hazardous Waste not in Containers
8
Documentation
Common ViolationsLQG
ndash Job Descriptionsndash LQG contingency plan
Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area
LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage
area(s) documented
Job Descriptions A written job description for each position
ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position
ndash Duties describe the HW responsibilities of the individual holding that position
ndash Match name(s) to current title
Container Inspection Records
The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other
factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)
SQGLQG
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
Where is the Academic Labs Rule in Effect
Academic Labs Rule ndash Subpart K
In 2014 86 facilities are currently operating under Subpart Kbull 56 are collegesuniversitiesbull 10 are teaching hospitals onlybull 13 are non-profit research institute onlybull 2 are collegeuniversity w a teaching hospitalbull 5 are teaching hospital and non-profit research
institute
Where is the Solvent Contaminated Wipe Rule in Effect
Summary of EPArsquosAudit Policy
Revised Policy1048708 65 FR 19617 - Effective May 11 20001048708 wwwepagovcomplianceincentivesauditingauditpolicyhtml
Incentives under Policy Penalty mitigation
No recommendation for criminal prosecution
No routine requests for audit reports
Conditions of the Audit Policy Entities that satisfy all the following conditions
are eligible for 100 penalty mitigation EPA retains its discretion to collect any economic benefit that may have been
realized as a result of non-compliance
Entities that satisfy all but the first condition -- systematic discovery -- are eligible for 75 penalty mitigation
Condition
Number
Short-Hand Summary ofAudit Policy Conditions
1
Systematic Discovery of the violation through an environmental audit or a compliance management system
2Voluntary Discovery in other words it is not through a legally required monitoring sampling or auditing procedure
3
Prompt Disclosure in writing to EPA within 21 days of discovery or any shorter time required by law
4 Independent Discovery and Disclosure
5
Correction and Remediation within 60 days in most cases from date of discovery
6 Prevent recurrence of a violation
7
Repeat violations are not eligible for mitigation under the Audit Policy
8 Certain violations are not eligible
9 Cooperation by the disclosing entity is required
Conditions of Policy
1 Systematic Discovery of the violation through an environmental audit or a compliance management system
2 Voluntary Discovery that is not through a legally required monitoring sampling or auditing procedure
Conditions of Policy cont
3 Prompt disclosure in writing to EPA within 21 days of discovery or any shorter time required by law
bull Discovery occurs when any officer director employee or agent of the facility has an objectively reasonable basis for believing that a violation has or may have occurred
Conditions of Policy cont
4 Independent discovery and disclosure before EPA likely would have identified the violation through its own investigation or based on information from a third party
5 Correction and remediation within 60 days in most cases from date of discovery
Conditions of Policy cont
6 Prevent recurrence of violation
7 Repeat violations are not eligible that is violations that occurred within the past 3 years at the same facility or as part of a pattern of violations within the past 5 years at facilities owned or operated by the same company
Conditions of Policy cont
8 Certain violations are not eligible -- those that result in serious actual harm that may have presented an imminent and substantial endangerment or that violate specific terms of an administrative or judicial order or consent agreement
9 Cooperation by the disclosing entity is required
State Self Reporting Policy
Your state may have a self reporting policy similar to the federal policy
May need to notify through both EPA and your State to receive any penalty mitigation
Things you need to do Get the inspector in amp out as quickly as
possible
Keep your records neat and orderly
Ensure records are available for review bull Location of records must be known by several
people
Audit those that transport and receive your waste (HW UW E-waste amp non-haz)
Read the Inspectorrsquos Report
SQG vs LQG Paperwork RequirementsSmall Quantity Generator
bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with
local emergency authorities
bull Emergency Info posted by a phone
bull Employees must be thoroughly familiarhellip
Large Quantity Generator
bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with
local emergency authoritiesbull Contingency Plan
bull Documented RCRA Training job descriptions
bull Biennial Reportbull Waste Min Plan (Written)
Waste minimization certification for both SQGs amp LQGs
Common Violation
Item 13 Waste Codesbull Enter up to six federalstate
waste codes to describe each waste stream identified in Item 9bndash State waste codes that are
not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste
ndash No specific required order or hierarchy for state and federal waste codes
Manifests vs LDRs
Manifests and Land Disposal Restrictions are inter-connected but separate rules
40 CFR 26220 Appendix vs 2689(b)
Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005
Manifests HW Storage Limits SQGs only
40 CFR 26234(e)Allows storage of HW for 270 days when being
transported gt 200 miles an additional 90 days
40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit
LQG 90-Day Storage Limit
40 CFR 26234(b)
Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo
Exceeding the time limit is a MAJOR violation
Hospitals
Hazardous Waste Pharmaceutical Management Standards
The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities
ndash Proposed rule anticipated publication date August 2013
Hazardous Waste Pharmaceutical Management Standards
For more information
httpwwwepagovoswhazardgenerationpharmaceuticalshtm
Waste Generated at Hospitals
Using a MSDS for Waste Determinations
OSHA regs do not require manufacturers to identify constituents present in material at concentrations below
ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)
The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS
Salts and Esters not P-listed
If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated
Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products
EPA Guidance RO12155
Epinephrine Salts
P042 listing (Epinephrine) does not apply to Epinephrine salts
Most or all Epi-pens are Epinephrine salts
EPA Guidance RO14788
Using CAS Number for Waste Determinations
Formaldehyde (CAS No 50-00-0)ndash U122 when unused
If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of
formaldehyde when disposed of amp = U122
EPA Guidance RO13658
Silver Recovery Units
Low Level Mixed Waste - LLMW
Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste
Only applies to facilities with NRC permits Notification is required if conditional
exemption is claimed Read the Rule There are conditions to to
be met
Conditions for LLMW
Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N
Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste
10 Common RCRA Violations
10
Emergency Arrangements (esp Small Quantity Generators)
Arrangements with Local Authorities
26537
The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations
SQG
LQG
Arrangements with Local Authorities(40 CFR 26537)
Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams
Layout of the facilityProperties amp associated hazards of
hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes
Arrangements with Local Authorities - Hospitals
Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the
facilityndash The types of injuries or illnesses which could result
from fires explosions or releases at the facility
9
Hazardous Waste not in Containers
8
Documentation
Common ViolationsLQG
ndash Job Descriptionsndash LQG contingency plan
Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area
LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage
area(s) documented
Job Descriptions A written job description for each position
ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position
ndash Duties describe the HW responsibilities of the individual holding that position
ndash Match name(s) to current title
Container Inspection Records
The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other
factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)
SQGLQG
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
Academic Labs Rule ndash Subpart K
In 2014 86 facilities are currently operating under Subpart Kbull 56 are collegesuniversitiesbull 10 are teaching hospitals onlybull 13 are non-profit research institute onlybull 2 are collegeuniversity w a teaching hospitalbull 5 are teaching hospital and non-profit research
institute
Where is the Solvent Contaminated Wipe Rule in Effect
Summary of EPArsquosAudit Policy
Revised Policy1048708 65 FR 19617 - Effective May 11 20001048708 wwwepagovcomplianceincentivesauditingauditpolicyhtml
Incentives under Policy Penalty mitigation
No recommendation for criminal prosecution
No routine requests for audit reports
Conditions of the Audit Policy Entities that satisfy all the following conditions
are eligible for 100 penalty mitigation EPA retains its discretion to collect any economic benefit that may have been
realized as a result of non-compliance
Entities that satisfy all but the first condition -- systematic discovery -- are eligible for 75 penalty mitigation
Condition
Number
Short-Hand Summary ofAudit Policy Conditions
1
Systematic Discovery of the violation through an environmental audit or a compliance management system
2Voluntary Discovery in other words it is not through a legally required monitoring sampling or auditing procedure
3
Prompt Disclosure in writing to EPA within 21 days of discovery or any shorter time required by law
4 Independent Discovery and Disclosure
5
Correction and Remediation within 60 days in most cases from date of discovery
6 Prevent recurrence of a violation
7
Repeat violations are not eligible for mitigation under the Audit Policy
8 Certain violations are not eligible
9 Cooperation by the disclosing entity is required
Conditions of Policy
1 Systematic Discovery of the violation through an environmental audit or a compliance management system
2 Voluntary Discovery that is not through a legally required monitoring sampling or auditing procedure
Conditions of Policy cont
3 Prompt disclosure in writing to EPA within 21 days of discovery or any shorter time required by law
bull Discovery occurs when any officer director employee or agent of the facility has an objectively reasonable basis for believing that a violation has or may have occurred
Conditions of Policy cont
4 Independent discovery and disclosure before EPA likely would have identified the violation through its own investigation or based on information from a third party
5 Correction and remediation within 60 days in most cases from date of discovery
Conditions of Policy cont
6 Prevent recurrence of violation
7 Repeat violations are not eligible that is violations that occurred within the past 3 years at the same facility or as part of a pattern of violations within the past 5 years at facilities owned or operated by the same company
Conditions of Policy cont
8 Certain violations are not eligible -- those that result in serious actual harm that may have presented an imminent and substantial endangerment or that violate specific terms of an administrative or judicial order or consent agreement
9 Cooperation by the disclosing entity is required
State Self Reporting Policy
Your state may have a self reporting policy similar to the federal policy
May need to notify through both EPA and your State to receive any penalty mitigation
Things you need to do Get the inspector in amp out as quickly as
possible
Keep your records neat and orderly
Ensure records are available for review bull Location of records must be known by several
people
Audit those that transport and receive your waste (HW UW E-waste amp non-haz)
Read the Inspectorrsquos Report
SQG vs LQG Paperwork RequirementsSmall Quantity Generator
bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with
local emergency authorities
bull Emergency Info posted by a phone
bull Employees must be thoroughly familiarhellip
Large Quantity Generator
bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with
local emergency authoritiesbull Contingency Plan
bull Documented RCRA Training job descriptions
bull Biennial Reportbull Waste Min Plan (Written)
Waste minimization certification for both SQGs amp LQGs
Common Violation
Item 13 Waste Codesbull Enter up to six federalstate
waste codes to describe each waste stream identified in Item 9bndash State waste codes that are
not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste
ndash No specific required order or hierarchy for state and federal waste codes
Manifests vs LDRs
Manifests and Land Disposal Restrictions are inter-connected but separate rules
40 CFR 26220 Appendix vs 2689(b)
Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005
Manifests HW Storage Limits SQGs only
40 CFR 26234(e)Allows storage of HW for 270 days when being
transported gt 200 miles an additional 90 days
40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit
LQG 90-Day Storage Limit
40 CFR 26234(b)
Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo
Exceeding the time limit is a MAJOR violation
Hospitals
Hazardous Waste Pharmaceutical Management Standards
The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities
ndash Proposed rule anticipated publication date August 2013
Hazardous Waste Pharmaceutical Management Standards
For more information
httpwwwepagovoswhazardgenerationpharmaceuticalshtm
Waste Generated at Hospitals
Using a MSDS for Waste Determinations
OSHA regs do not require manufacturers to identify constituents present in material at concentrations below
ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)
The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS
Salts and Esters not P-listed
If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated
Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products
EPA Guidance RO12155
Epinephrine Salts
P042 listing (Epinephrine) does not apply to Epinephrine salts
Most or all Epi-pens are Epinephrine salts
EPA Guidance RO14788
Using CAS Number for Waste Determinations
Formaldehyde (CAS No 50-00-0)ndash U122 when unused
If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of
formaldehyde when disposed of amp = U122
EPA Guidance RO13658
Silver Recovery Units
Low Level Mixed Waste - LLMW
Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste
Only applies to facilities with NRC permits Notification is required if conditional
exemption is claimed Read the Rule There are conditions to to
be met
Conditions for LLMW
Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N
Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste
10 Common RCRA Violations
10
Emergency Arrangements (esp Small Quantity Generators)
Arrangements with Local Authorities
26537
The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations
SQG
LQG
Arrangements with Local Authorities(40 CFR 26537)
Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams
Layout of the facilityProperties amp associated hazards of
hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes
Arrangements with Local Authorities - Hospitals
Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the
facilityndash The types of injuries or illnesses which could result
from fires explosions or releases at the facility
9
Hazardous Waste not in Containers
8
Documentation
Common ViolationsLQG
ndash Job Descriptionsndash LQG contingency plan
Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area
LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage
area(s) documented
Job Descriptions A written job description for each position
ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position
ndash Duties describe the HW responsibilities of the individual holding that position
ndash Match name(s) to current title
Container Inspection Records
The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other
factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)
SQGLQG
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
Where is the Solvent Contaminated Wipe Rule in Effect
Summary of EPArsquosAudit Policy
Revised Policy1048708 65 FR 19617 - Effective May 11 20001048708 wwwepagovcomplianceincentivesauditingauditpolicyhtml
Incentives under Policy Penalty mitigation
No recommendation for criminal prosecution
No routine requests for audit reports
Conditions of the Audit Policy Entities that satisfy all the following conditions
are eligible for 100 penalty mitigation EPA retains its discretion to collect any economic benefit that may have been
realized as a result of non-compliance
Entities that satisfy all but the first condition -- systematic discovery -- are eligible for 75 penalty mitigation
Condition
Number
Short-Hand Summary ofAudit Policy Conditions
1
Systematic Discovery of the violation through an environmental audit or a compliance management system
2Voluntary Discovery in other words it is not through a legally required monitoring sampling or auditing procedure
3
Prompt Disclosure in writing to EPA within 21 days of discovery or any shorter time required by law
4 Independent Discovery and Disclosure
5
Correction and Remediation within 60 days in most cases from date of discovery
6 Prevent recurrence of a violation
7
Repeat violations are not eligible for mitigation under the Audit Policy
8 Certain violations are not eligible
9 Cooperation by the disclosing entity is required
Conditions of Policy
1 Systematic Discovery of the violation through an environmental audit or a compliance management system
2 Voluntary Discovery that is not through a legally required monitoring sampling or auditing procedure
Conditions of Policy cont
3 Prompt disclosure in writing to EPA within 21 days of discovery or any shorter time required by law
bull Discovery occurs when any officer director employee or agent of the facility has an objectively reasonable basis for believing that a violation has or may have occurred
Conditions of Policy cont
4 Independent discovery and disclosure before EPA likely would have identified the violation through its own investigation or based on information from a third party
5 Correction and remediation within 60 days in most cases from date of discovery
Conditions of Policy cont
6 Prevent recurrence of violation
7 Repeat violations are not eligible that is violations that occurred within the past 3 years at the same facility or as part of a pattern of violations within the past 5 years at facilities owned or operated by the same company
Conditions of Policy cont
8 Certain violations are not eligible -- those that result in serious actual harm that may have presented an imminent and substantial endangerment or that violate specific terms of an administrative or judicial order or consent agreement
9 Cooperation by the disclosing entity is required
State Self Reporting Policy
Your state may have a self reporting policy similar to the federal policy
May need to notify through both EPA and your State to receive any penalty mitigation
Things you need to do Get the inspector in amp out as quickly as
possible
Keep your records neat and orderly
Ensure records are available for review bull Location of records must be known by several
people
Audit those that transport and receive your waste (HW UW E-waste amp non-haz)
Read the Inspectorrsquos Report
SQG vs LQG Paperwork RequirementsSmall Quantity Generator
bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with
local emergency authorities
bull Emergency Info posted by a phone
bull Employees must be thoroughly familiarhellip
Large Quantity Generator
bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with
local emergency authoritiesbull Contingency Plan
bull Documented RCRA Training job descriptions
bull Biennial Reportbull Waste Min Plan (Written)
Waste minimization certification for both SQGs amp LQGs
Common Violation
Item 13 Waste Codesbull Enter up to six federalstate
waste codes to describe each waste stream identified in Item 9bndash State waste codes that are
not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste
ndash No specific required order or hierarchy for state and federal waste codes
Manifests vs LDRs
Manifests and Land Disposal Restrictions are inter-connected but separate rules
40 CFR 26220 Appendix vs 2689(b)
Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005
Manifests HW Storage Limits SQGs only
40 CFR 26234(e)Allows storage of HW for 270 days when being
transported gt 200 miles an additional 90 days
40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit
LQG 90-Day Storage Limit
40 CFR 26234(b)
Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo
Exceeding the time limit is a MAJOR violation
Hospitals
Hazardous Waste Pharmaceutical Management Standards
The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities
ndash Proposed rule anticipated publication date August 2013
Hazardous Waste Pharmaceutical Management Standards
For more information
httpwwwepagovoswhazardgenerationpharmaceuticalshtm
Waste Generated at Hospitals
Using a MSDS for Waste Determinations
OSHA regs do not require manufacturers to identify constituents present in material at concentrations below
ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)
The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS
Salts and Esters not P-listed
If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated
Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products
EPA Guidance RO12155
Epinephrine Salts
P042 listing (Epinephrine) does not apply to Epinephrine salts
Most or all Epi-pens are Epinephrine salts
EPA Guidance RO14788
Using CAS Number for Waste Determinations
Formaldehyde (CAS No 50-00-0)ndash U122 when unused
If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of
formaldehyde when disposed of amp = U122
EPA Guidance RO13658
Silver Recovery Units
Low Level Mixed Waste - LLMW
Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste
Only applies to facilities with NRC permits Notification is required if conditional
exemption is claimed Read the Rule There are conditions to to
be met
Conditions for LLMW
Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N
Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste
10 Common RCRA Violations
10
Emergency Arrangements (esp Small Quantity Generators)
Arrangements with Local Authorities
26537
The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations
SQG
LQG
Arrangements with Local Authorities(40 CFR 26537)
Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams
Layout of the facilityProperties amp associated hazards of
hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes
Arrangements with Local Authorities - Hospitals
Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the
facilityndash The types of injuries or illnesses which could result
from fires explosions or releases at the facility
9
Hazardous Waste not in Containers
8
Documentation
Common ViolationsLQG
ndash Job Descriptionsndash LQG contingency plan
Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area
LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage
area(s) documented
Job Descriptions A written job description for each position
ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position
ndash Duties describe the HW responsibilities of the individual holding that position
ndash Match name(s) to current title
Container Inspection Records
The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other
factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)
SQGLQG
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
Summary of EPArsquosAudit Policy
Revised Policy1048708 65 FR 19617 - Effective May 11 20001048708 wwwepagovcomplianceincentivesauditingauditpolicyhtml
Incentives under Policy Penalty mitigation
No recommendation for criminal prosecution
No routine requests for audit reports
Conditions of the Audit Policy Entities that satisfy all the following conditions
are eligible for 100 penalty mitigation EPA retains its discretion to collect any economic benefit that may have been
realized as a result of non-compliance
Entities that satisfy all but the first condition -- systematic discovery -- are eligible for 75 penalty mitigation
Condition
Number
Short-Hand Summary ofAudit Policy Conditions
1
Systematic Discovery of the violation through an environmental audit or a compliance management system
2Voluntary Discovery in other words it is not through a legally required monitoring sampling or auditing procedure
3
Prompt Disclosure in writing to EPA within 21 days of discovery or any shorter time required by law
4 Independent Discovery and Disclosure
5
Correction and Remediation within 60 days in most cases from date of discovery
6 Prevent recurrence of a violation
7
Repeat violations are not eligible for mitigation under the Audit Policy
8 Certain violations are not eligible
9 Cooperation by the disclosing entity is required
Conditions of Policy
1 Systematic Discovery of the violation through an environmental audit or a compliance management system
2 Voluntary Discovery that is not through a legally required monitoring sampling or auditing procedure
Conditions of Policy cont
3 Prompt disclosure in writing to EPA within 21 days of discovery or any shorter time required by law
bull Discovery occurs when any officer director employee or agent of the facility has an objectively reasonable basis for believing that a violation has or may have occurred
Conditions of Policy cont
4 Independent discovery and disclosure before EPA likely would have identified the violation through its own investigation or based on information from a third party
5 Correction and remediation within 60 days in most cases from date of discovery
Conditions of Policy cont
6 Prevent recurrence of violation
7 Repeat violations are not eligible that is violations that occurred within the past 3 years at the same facility or as part of a pattern of violations within the past 5 years at facilities owned or operated by the same company
Conditions of Policy cont
8 Certain violations are not eligible -- those that result in serious actual harm that may have presented an imminent and substantial endangerment or that violate specific terms of an administrative or judicial order or consent agreement
9 Cooperation by the disclosing entity is required
State Self Reporting Policy
Your state may have a self reporting policy similar to the federal policy
May need to notify through both EPA and your State to receive any penalty mitigation
Things you need to do Get the inspector in amp out as quickly as
possible
Keep your records neat and orderly
Ensure records are available for review bull Location of records must be known by several
people
Audit those that transport and receive your waste (HW UW E-waste amp non-haz)
Read the Inspectorrsquos Report
SQG vs LQG Paperwork RequirementsSmall Quantity Generator
bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with
local emergency authorities
bull Emergency Info posted by a phone
bull Employees must be thoroughly familiarhellip
Large Quantity Generator
bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with
local emergency authoritiesbull Contingency Plan
bull Documented RCRA Training job descriptions
bull Biennial Reportbull Waste Min Plan (Written)
Waste minimization certification for both SQGs amp LQGs
Common Violation
Item 13 Waste Codesbull Enter up to six federalstate
waste codes to describe each waste stream identified in Item 9bndash State waste codes that are
not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste
ndash No specific required order or hierarchy for state and federal waste codes
Manifests vs LDRs
Manifests and Land Disposal Restrictions are inter-connected but separate rules
40 CFR 26220 Appendix vs 2689(b)
Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005
Manifests HW Storage Limits SQGs only
40 CFR 26234(e)Allows storage of HW for 270 days when being
transported gt 200 miles an additional 90 days
40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit
LQG 90-Day Storage Limit
40 CFR 26234(b)
Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo
Exceeding the time limit is a MAJOR violation
Hospitals
Hazardous Waste Pharmaceutical Management Standards
The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities
ndash Proposed rule anticipated publication date August 2013
Hazardous Waste Pharmaceutical Management Standards
For more information
httpwwwepagovoswhazardgenerationpharmaceuticalshtm
Waste Generated at Hospitals
Using a MSDS for Waste Determinations
OSHA regs do not require manufacturers to identify constituents present in material at concentrations below
ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)
The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS
Salts and Esters not P-listed
If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated
Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products
EPA Guidance RO12155
Epinephrine Salts
P042 listing (Epinephrine) does not apply to Epinephrine salts
Most or all Epi-pens are Epinephrine salts
EPA Guidance RO14788
Using CAS Number for Waste Determinations
Formaldehyde (CAS No 50-00-0)ndash U122 when unused
If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of
formaldehyde when disposed of amp = U122
EPA Guidance RO13658
Silver Recovery Units
Low Level Mixed Waste - LLMW
Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste
Only applies to facilities with NRC permits Notification is required if conditional
exemption is claimed Read the Rule There are conditions to to
be met
Conditions for LLMW
Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N
Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste
10 Common RCRA Violations
10
Emergency Arrangements (esp Small Quantity Generators)
Arrangements with Local Authorities
26537
The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations
SQG
LQG
Arrangements with Local Authorities(40 CFR 26537)
Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams
Layout of the facilityProperties amp associated hazards of
hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes
Arrangements with Local Authorities - Hospitals
Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the
facilityndash The types of injuries or illnesses which could result
from fires explosions or releases at the facility
9
Hazardous Waste not in Containers
8
Documentation
Common ViolationsLQG
ndash Job Descriptionsndash LQG contingency plan
Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area
LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage
area(s) documented
Job Descriptions A written job description for each position
ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position
ndash Duties describe the HW responsibilities of the individual holding that position
ndash Match name(s) to current title
Container Inspection Records
The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other
factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)
SQGLQG
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
Incentives under Policy Penalty mitigation
No recommendation for criminal prosecution
No routine requests for audit reports
Conditions of the Audit Policy Entities that satisfy all the following conditions
are eligible for 100 penalty mitigation EPA retains its discretion to collect any economic benefit that may have been
realized as a result of non-compliance
Entities that satisfy all but the first condition -- systematic discovery -- are eligible for 75 penalty mitigation
Condition
Number
Short-Hand Summary ofAudit Policy Conditions
1
Systematic Discovery of the violation through an environmental audit or a compliance management system
2Voluntary Discovery in other words it is not through a legally required monitoring sampling or auditing procedure
3
Prompt Disclosure in writing to EPA within 21 days of discovery or any shorter time required by law
4 Independent Discovery and Disclosure
5
Correction and Remediation within 60 days in most cases from date of discovery
6 Prevent recurrence of a violation
7
Repeat violations are not eligible for mitigation under the Audit Policy
8 Certain violations are not eligible
9 Cooperation by the disclosing entity is required
Conditions of Policy
1 Systematic Discovery of the violation through an environmental audit or a compliance management system
2 Voluntary Discovery that is not through a legally required monitoring sampling or auditing procedure
Conditions of Policy cont
3 Prompt disclosure in writing to EPA within 21 days of discovery or any shorter time required by law
bull Discovery occurs when any officer director employee or agent of the facility has an objectively reasonable basis for believing that a violation has or may have occurred
Conditions of Policy cont
4 Independent discovery and disclosure before EPA likely would have identified the violation through its own investigation or based on information from a third party
5 Correction and remediation within 60 days in most cases from date of discovery
Conditions of Policy cont
6 Prevent recurrence of violation
7 Repeat violations are not eligible that is violations that occurred within the past 3 years at the same facility or as part of a pattern of violations within the past 5 years at facilities owned or operated by the same company
Conditions of Policy cont
8 Certain violations are not eligible -- those that result in serious actual harm that may have presented an imminent and substantial endangerment or that violate specific terms of an administrative or judicial order or consent agreement
9 Cooperation by the disclosing entity is required
State Self Reporting Policy
Your state may have a self reporting policy similar to the federal policy
May need to notify through both EPA and your State to receive any penalty mitigation
Things you need to do Get the inspector in amp out as quickly as
possible
Keep your records neat and orderly
Ensure records are available for review bull Location of records must be known by several
people
Audit those that transport and receive your waste (HW UW E-waste amp non-haz)
Read the Inspectorrsquos Report
SQG vs LQG Paperwork RequirementsSmall Quantity Generator
bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with
local emergency authorities
bull Emergency Info posted by a phone
bull Employees must be thoroughly familiarhellip
Large Quantity Generator
bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with
local emergency authoritiesbull Contingency Plan
bull Documented RCRA Training job descriptions
bull Biennial Reportbull Waste Min Plan (Written)
Waste minimization certification for both SQGs amp LQGs
Common Violation
Item 13 Waste Codesbull Enter up to six federalstate
waste codes to describe each waste stream identified in Item 9bndash State waste codes that are
not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste
ndash No specific required order or hierarchy for state and federal waste codes
Manifests vs LDRs
Manifests and Land Disposal Restrictions are inter-connected but separate rules
40 CFR 26220 Appendix vs 2689(b)
Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005
Manifests HW Storage Limits SQGs only
40 CFR 26234(e)Allows storage of HW for 270 days when being
transported gt 200 miles an additional 90 days
40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit
LQG 90-Day Storage Limit
40 CFR 26234(b)
Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo
Exceeding the time limit is a MAJOR violation
Hospitals
Hazardous Waste Pharmaceutical Management Standards
The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities
ndash Proposed rule anticipated publication date August 2013
Hazardous Waste Pharmaceutical Management Standards
For more information
httpwwwepagovoswhazardgenerationpharmaceuticalshtm
Waste Generated at Hospitals
Using a MSDS for Waste Determinations
OSHA regs do not require manufacturers to identify constituents present in material at concentrations below
ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)
The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS
Salts and Esters not P-listed
If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated
Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products
EPA Guidance RO12155
Epinephrine Salts
P042 listing (Epinephrine) does not apply to Epinephrine salts
Most or all Epi-pens are Epinephrine salts
EPA Guidance RO14788
Using CAS Number for Waste Determinations
Formaldehyde (CAS No 50-00-0)ndash U122 when unused
If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of
formaldehyde when disposed of amp = U122
EPA Guidance RO13658
Silver Recovery Units
Low Level Mixed Waste - LLMW
Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste
Only applies to facilities with NRC permits Notification is required if conditional
exemption is claimed Read the Rule There are conditions to to
be met
Conditions for LLMW
Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N
Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste
10 Common RCRA Violations
10
Emergency Arrangements (esp Small Quantity Generators)
Arrangements with Local Authorities
26537
The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations
SQG
LQG
Arrangements with Local Authorities(40 CFR 26537)
Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams
Layout of the facilityProperties amp associated hazards of
hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes
Arrangements with Local Authorities - Hospitals
Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the
facilityndash The types of injuries or illnesses which could result
from fires explosions or releases at the facility
9
Hazardous Waste not in Containers
8
Documentation
Common ViolationsLQG
ndash Job Descriptionsndash LQG contingency plan
Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area
LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage
area(s) documented
Job Descriptions A written job description for each position
ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position
ndash Duties describe the HW responsibilities of the individual holding that position
ndash Match name(s) to current title
Container Inspection Records
The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other
factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)
SQGLQG
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
Conditions of the Audit Policy Entities that satisfy all the following conditions
are eligible for 100 penalty mitigation EPA retains its discretion to collect any economic benefit that may have been
realized as a result of non-compliance
Entities that satisfy all but the first condition -- systematic discovery -- are eligible for 75 penalty mitigation
Condition
Number
Short-Hand Summary ofAudit Policy Conditions
1
Systematic Discovery of the violation through an environmental audit or a compliance management system
2Voluntary Discovery in other words it is not through a legally required monitoring sampling or auditing procedure
3
Prompt Disclosure in writing to EPA within 21 days of discovery or any shorter time required by law
4 Independent Discovery and Disclosure
5
Correction and Remediation within 60 days in most cases from date of discovery
6 Prevent recurrence of a violation
7
Repeat violations are not eligible for mitigation under the Audit Policy
8 Certain violations are not eligible
9 Cooperation by the disclosing entity is required
Conditions of Policy
1 Systematic Discovery of the violation through an environmental audit or a compliance management system
2 Voluntary Discovery that is not through a legally required monitoring sampling or auditing procedure
Conditions of Policy cont
3 Prompt disclosure in writing to EPA within 21 days of discovery or any shorter time required by law
bull Discovery occurs when any officer director employee or agent of the facility has an objectively reasonable basis for believing that a violation has or may have occurred
Conditions of Policy cont
4 Independent discovery and disclosure before EPA likely would have identified the violation through its own investigation or based on information from a third party
5 Correction and remediation within 60 days in most cases from date of discovery
Conditions of Policy cont
6 Prevent recurrence of violation
7 Repeat violations are not eligible that is violations that occurred within the past 3 years at the same facility or as part of a pattern of violations within the past 5 years at facilities owned or operated by the same company
Conditions of Policy cont
8 Certain violations are not eligible -- those that result in serious actual harm that may have presented an imminent and substantial endangerment or that violate specific terms of an administrative or judicial order or consent agreement
9 Cooperation by the disclosing entity is required
State Self Reporting Policy
Your state may have a self reporting policy similar to the federal policy
May need to notify through both EPA and your State to receive any penalty mitigation
Things you need to do Get the inspector in amp out as quickly as
possible
Keep your records neat and orderly
Ensure records are available for review bull Location of records must be known by several
people
Audit those that transport and receive your waste (HW UW E-waste amp non-haz)
Read the Inspectorrsquos Report
SQG vs LQG Paperwork RequirementsSmall Quantity Generator
bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with
local emergency authorities
bull Emergency Info posted by a phone
bull Employees must be thoroughly familiarhellip
Large Quantity Generator
bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with
local emergency authoritiesbull Contingency Plan
bull Documented RCRA Training job descriptions
bull Biennial Reportbull Waste Min Plan (Written)
Waste minimization certification for both SQGs amp LQGs
Common Violation
Item 13 Waste Codesbull Enter up to six federalstate
waste codes to describe each waste stream identified in Item 9bndash State waste codes that are
not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste
ndash No specific required order or hierarchy for state and federal waste codes
Manifests vs LDRs
Manifests and Land Disposal Restrictions are inter-connected but separate rules
40 CFR 26220 Appendix vs 2689(b)
Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005
Manifests HW Storage Limits SQGs only
40 CFR 26234(e)Allows storage of HW for 270 days when being
transported gt 200 miles an additional 90 days
40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit
LQG 90-Day Storage Limit
40 CFR 26234(b)
Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo
Exceeding the time limit is a MAJOR violation
Hospitals
Hazardous Waste Pharmaceutical Management Standards
The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities
ndash Proposed rule anticipated publication date August 2013
Hazardous Waste Pharmaceutical Management Standards
For more information
httpwwwepagovoswhazardgenerationpharmaceuticalshtm
Waste Generated at Hospitals
Using a MSDS for Waste Determinations
OSHA regs do not require manufacturers to identify constituents present in material at concentrations below
ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)
The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS
Salts and Esters not P-listed
If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated
Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products
EPA Guidance RO12155
Epinephrine Salts
P042 listing (Epinephrine) does not apply to Epinephrine salts
Most or all Epi-pens are Epinephrine salts
EPA Guidance RO14788
Using CAS Number for Waste Determinations
Formaldehyde (CAS No 50-00-0)ndash U122 when unused
If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of
formaldehyde when disposed of amp = U122
EPA Guidance RO13658
Silver Recovery Units
Low Level Mixed Waste - LLMW
Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste
Only applies to facilities with NRC permits Notification is required if conditional
exemption is claimed Read the Rule There are conditions to to
be met
Conditions for LLMW
Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N
Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste
10 Common RCRA Violations
10
Emergency Arrangements (esp Small Quantity Generators)
Arrangements with Local Authorities
26537
The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations
SQG
LQG
Arrangements with Local Authorities(40 CFR 26537)
Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams
Layout of the facilityProperties amp associated hazards of
hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes
Arrangements with Local Authorities - Hospitals
Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the
facilityndash The types of injuries or illnesses which could result
from fires explosions or releases at the facility
9
Hazardous Waste not in Containers
8
Documentation
Common ViolationsLQG
ndash Job Descriptionsndash LQG contingency plan
Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area
LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage
area(s) documented
Job Descriptions A written job description for each position
ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position
ndash Duties describe the HW responsibilities of the individual holding that position
ndash Match name(s) to current title
Container Inspection Records
The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other
factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)
SQGLQG
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
Condition
Number
Short-Hand Summary ofAudit Policy Conditions
1
Systematic Discovery of the violation through an environmental audit or a compliance management system
2Voluntary Discovery in other words it is not through a legally required monitoring sampling or auditing procedure
3
Prompt Disclosure in writing to EPA within 21 days of discovery or any shorter time required by law
4 Independent Discovery and Disclosure
5
Correction and Remediation within 60 days in most cases from date of discovery
6 Prevent recurrence of a violation
7
Repeat violations are not eligible for mitigation under the Audit Policy
8 Certain violations are not eligible
9 Cooperation by the disclosing entity is required
Conditions of Policy
1 Systematic Discovery of the violation through an environmental audit or a compliance management system
2 Voluntary Discovery that is not through a legally required monitoring sampling or auditing procedure
Conditions of Policy cont
3 Prompt disclosure in writing to EPA within 21 days of discovery or any shorter time required by law
bull Discovery occurs when any officer director employee or agent of the facility has an objectively reasonable basis for believing that a violation has or may have occurred
Conditions of Policy cont
4 Independent discovery and disclosure before EPA likely would have identified the violation through its own investigation or based on information from a third party
5 Correction and remediation within 60 days in most cases from date of discovery
Conditions of Policy cont
6 Prevent recurrence of violation
7 Repeat violations are not eligible that is violations that occurred within the past 3 years at the same facility or as part of a pattern of violations within the past 5 years at facilities owned or operated by the same company
Conditions of Policy cont
8 Certain violations are not eligible -- those that result in serious actual harm that may have presented an imminent and substantial endangerment or that violate specific terms of an administrative or judicial order or consent agreement
9 Cooperation by the disclosing entity is required
State Self Reporting Policy
Your state may have a self reporting policy similar to the federal policy
May need to notify through both EPA and your State to receive any penalty mitigation
Things you need to do Get the inspector in amp out as quickly as
possible
Keep your records neat and orderly
Ensure records are available for review bull Location of records must be known by several
people
Audit those that transport and receive your waste (HW UW E-waste amp non-haz)
Read the Inspectorrsquos Report
SQG vs LQG Paperwork RequirementsSmall Quantity Generator
bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with
local emergency authorities
bull Emergency Info posted by a phone
bull Employees must be thoroughly familiarhellip
Large Quantity Generator
bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with
local emergency authoritiesbull Contingency Plan
bull Documented RCRA Training job descriptions
bull Biennial Reportbull Waste Min Plan (Written)
Waste minimization certification for both SQGs amp LQGs
Common Violation
Item 13 Waste Codesbull Enter up to six federalstate
waste codes to describe each waste stream identified in Item 9bndash State waste codes that are
not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste
ndash No specific required order or hierarchy for state and federal waste codes
Manifests vs LDRs
Manifests and Land Disposal Restrictions are inter-connected but separate rules
40 CFR 26220 Appendix vs 2689(b)
Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005
Manifests HW Storage Limits SQGs only
40 CFR 26234(e)Allows storage of HW for 270 days when being
transported gt 200 miles an additional 90 days
40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit
LQG 90-Day Storage Limit
40 CFR 26234(b)
Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo
Exceeding the time limit is a MAJOR violation
Hospitals
Hazardous Waste Pharmaceutical Management Standards
The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities
ndash Proposed rule anticipated publication date August 2013
Hazardous Waste Pharmaceutical Management Standards
For more information
httpwwwepagovoswhazardgenerationpharmaceuticalshtm
Waste Generated at Hospitals
Using a MSDS for Waste Determinations
OSHA regs do not require manufacturers to identify constituents present in material at concentrations below
ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)
The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS
Salts and Esters not P-listed
If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated
Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products
EPA Guidance RO12155
Epinephrine Salts
P042 listing (Epinephrine) does not apply to Epinephrine salts
Most or all Epi-pens are Epinephrine salts
EPA Guidance RO14788
Using CAS Number for Waste Determinations
Formaldehyde (CAS No 50-00-0)ndash U122 when unused
If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of
formaldehyde when disposed of amp = U122
EPA Guidance RO13658
Silver Recovery Units
Low Level Mixed Waste - LLMW
Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste
Only applies to facilities with NRC permits Notification is required if conditional
exemption is claimed Read the Rule There are conditions to to
be met
Conditions for LLMW
Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N
Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste
10 Common RCRA Violations
10
Emergency Arrangements (esp Small Quantity Generators)
Arrangements with Local Authorities
26537
The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations
SQG
LQG
Arrangements with Local Authorities(40 CFR 26537)
Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams
Layout of the facilityProperties amp associated hazards of
hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes
Arrangements with Local Authorities - Hospitals
Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the
facilityndash The types of injuries or illnesses which could result
from fires explosions or releases at the facility
9
Hazardous Waste not in Containers
8
Documentation
Common ViolationsLQG
ndash Job Descriptionsndash LQG contingency plan
Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area
LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage
area(s) documented
Job Descriptions A written job description for each position
ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position
ndash Duties describe the HW responsibilities of the individual holding that position
ndash Match name(s) to current title
Container Inspection Records
The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other
factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)
SQGLQG
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
Conditions of Policy
1 Systematic Discovery of the violation through an environmental audit or a compliance management system
2 Voluntary Discovery that is not through a legally required monitoring sampling or auditing procedure
Conditions of Policy cont
3 Prompt disclosure in writing to EPA within 21 days of discovery or any shorter time required by law
bull Discovery occurs when any officer director employee or agent of the facility has an objectively reasonable basis for believing that a violation has or may have occurred
Conditions of Policy cont
4 Independent discovery and disclosure before EPA likely would have identified the violation through its own investigation or based on information from a third party
5 Correction and remediation within 60 days in most cases from date of discovery
Conditions of Policy cont
6 Prevent recurrence of violation
7 Repeat violations are not eligible that is violations that occurred within the past 3 years at the same facility or as part of a pattern of violations within the past 5 years at facilities owned or operated by the same company
Conditions of Policy cont
8 Certain violations are not eligible -- those that result in serious actual harm that may have presented an imminent and substantial endangerment or that violate specific terms of an administrative or judicial order or consent agreement
9 Cooperation by the disclosing entity is required
State Self Reporting Policy
Your state may have a self reporting policy similar to the federal policy
May need to notify through both EPA and your State to receive any penalty mitigation
Things you need to do Get the inspector in amp out as quickly as
possible
Keep your records neat and orderly
Ensure records are available for review bull Location of records must be known by several
people
Audit those that transport and receive your waste (HW UW E-waste amp non-haz)
Read the Inspectorrsquos Report
SQG vs LQG Paperwork RequirementsSmall Quantity Generator
bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with
local emergency authorities
bull Emergency Info posted by a phone
bull Employees must be thoroughly familiarhellip
Large Quantity Generator
bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with
local emergency authoritiesbull Contingency Plan
bull Documented RCRA Training job descriptions
bull Biennial Reportbull Waste Min Plan (Written)
Waste minimization certification for both SQGs amp LQGs
Common Violation
Item 13 Waste Codesbull Enter up to six federalstate
waste codes to describe each waste stream identified in Item 9bndash State waste codes that are
not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste
ndash No specific required order or hierarchy for state and federal waste codes
Manifests vs LDRs
Manifests and Land Disposal Restrictions are inter-connected but separate rules
40 CFR 26220 Appendix vs 2689(b)
Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005
Manifests HW Storage Limits SQGs only
40 CFR 26234(e)Allows storage of HW for 270 days when being
transported gt 200 miles an additional 90 days
40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit
LQG 90-Day Storage Limit
40 CFR 26234(b)
Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo
Exceeding the time limit is a MAJOR violation
Hospitals
Hazardous Waste Pharmaceutical Management Standards
The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities
ndash Proposed rule anticipated publication date August 2013
Hazardous Waste Pharmaceutical Management Standards
For more information
httpwwwepagovoswhazardgenerationpharmaceuticalshtm
Waste Generated at Hospitals
Using a MSDS for Waste Determinations
OSHA regs do not require manufacturers to identify constituents present in material at concentrations below
ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)
The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS
Salts and Esters not P-listed
If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated
Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products
EPA Guidance RO12155
Epinephrine Salts
P042 listing (Epinephrine) does not apply to Epinephrine salts
Most or all Epi-pens are Epinephrine salts
EPA Guidance RO14788
Using CAS Number for Waste Determinations
Formaldehyde (CAS No 50-00-0)ndash U122 when unused
If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of
formaldehyde when disposed of amp = U122
EPA Guidance RO13658
Silver Recovery Units
Low Level Mixed Waste - LLMW
Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste
Only applies to facilities with NRC permits Notification is required if conditional
exemption is claimed Read the Rule There are conditions to to
be met
Conditions for LLMW
Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N
Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste
10 Common RCRA Violations
10
Emergency Arrangements (esp Small Quantity Generators)
Arrangements with Local Authorities
26537
The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations
SQG
LQG
Arrangements with Local Authorities(40 CFR 26537)
Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams
Layout of the facilityProperties amp associated hazards of
hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes
Arrangements with Local Authorities - Hospitals
Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the
facilityndash The types of injuries or illnesses which could result
from fires explosions or releases at the facility
9
Hazardous Waste not in Containers
8
Documentation
Common ViolationsLQG
ndash Job Descriptionsndash LQG contingency plan
Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area
LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage
area(s) documented
Job Descriptions A written job description for each position
ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position
ndash Duties describe the HW responsibilities of the individual holding that position
ndash Match name(s) to current title
Container Inspection Records
The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other
factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)
SQGLQG
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
Conditions of Policy cont
3 Prompt disclosure in writing to EPA within 21 days of discovery or any shorter time required by law
bull Discovery occurs when any officer director employee or agent of the facility has an objectively reasonable basis for believing that a violation has or may have occurred
Conditions of Policy cont
4 Independent discovery and disclosure before EPA likely would have identified the violation through its own investigation or based on information from a third party
5 Correction and remediation within 60 days in most cases from date of discovery
Conditions of Policy cont
6 Prevent recurrence of violation
7 Repeat violations are not eligible that is violations that occurred within the past 3 years at the same facility or as part of a pattern of violations within the past 5 years at facilities owned or operated by the same company
Conditions of Policy cont
8 Certain violations are not eligible -- those that result in serious actual harm that may have presented an imminent and substantial endangerment or that violate specific terms of an administrative or judicial order or consent agreement
9 Cooperation by the disclosing entity is required
State Self Reporting Policy
Your state may have a self reporting policy similar to the federal policy
May need to notify through both EPA and your State to receive any penalty mitigation
Things you need to do Get the inspector in amp out as quickly as
possible
Keep your records neat and orderly
Ensure records are available for review bull Location of records must be known by several
people
Audit those that transport and receive your waste (HW UW E-waste amp non-haz)
Read the Inspectorrsquos Report
SQG vs LQG Paperwork RequirementsSmall Quantity Generator
bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with
local emergency authorities
bull Emergency Info posted by a phone
bull Employees must be thoroughly familiarhellip
Large Quantity Generator
bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with
local emergency authoritiesbull Contingency Plan
bull Documented RCRA Training job descriptions
bull Biennial Reportbull Waste Min Plan (Written)
Waste minimization certification for both SQGs amp LQGs
Common Violation
Item 13 Waste Codesbull Enter up to six federalstate
waste codes to describe each waste stream identified in Item 9bndash State waste codes that are
not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste
ndash No specific required order or hierarchy for state and federal waste codes
Manifests vs LDRs
Manifests and Land Disposal Restrictions are inter-connected but separate rules
40 CFR 26220 Appendix vs 2689(b)
Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005
Manifests HW Storage Limits SQGs only
40 CFR 26234(e)Allows storage of HW for 270 days when being
transported gt 200 miles an additional 90 days
40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit
LQG 90-Day Storage Limit
40 CFR 26234(b)
Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo
Exceeding the time limit is a MAJOR violation
Hospitals
Hazardous Waste Pharmaceutical Management Standards
The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities
ndash Proposed rule anticipated publication date August 2013
Hazardous Waste Pharmaceutical Management Standards
For more information
httpwwwepagovoswhazardgenerationpharmaceuticalshtm
Waste Generated at Hospitals
Using a MSDS for Waste Determinations
OSHA regs do not require manufacturers to identify constituents present in material at concentrations below
ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)
The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS
Salts and Esters not P-listed
If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated
Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products
EPA Guidance RO12155
Epinephrine Salts
P042 listing (Epinephrine) does not apply to Epinephrine salts
Most or all Epi-pens are Epinephrine salts
EPA Guidance RO14788
Using CAS Number for Waste Determinations
Formaldehyde (CAS No 50-00-0)ndash U122 when unused
If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of
formaldehyde when disposed of amp = U122
EPA Guidance RO13658
Silver Recovery Units
Low Level Mixed Waste - LLMW
Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste
Only applies to facilities with NRC permits Notification is required if conditional
exemption is claimed Read the Rule There are conditions to to
be met
Conditions for LLMW
Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N
Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste
10 Common RCRA Violations
10
Emergency Arrangements (esp Small Quantity Generators)
Arrangements with Local Authorities
26537
The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations
SQG
LQG
Arrangements with Local Authorities(40 CFR 26537)
Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams
Layout of the facilityProperties amp associated hazards of
hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes
Arrangements with Local Authorities - Hospitals
Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the
facilityndash The types of injuries or illnesses which could result
from fires explosions or releases at the facility
9
Hazardous Waste not in Containers
8
Documentation
Common ViolationsLQG
ndash Job Descriptionsndash LQG contingency plan
Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area
LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage
area(s) documented
Job Descriptions A written job description for each position
ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position
ndash Duties describe the HW responsibilities of the individual holding that position
ndash Match name(s) to current title
Container Inspection Records
The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other
factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)
SQGLQG
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
Conditions of Policy cont
4 Independent discovery and disclosure before EPA likely would have identified the violation through its own investigation or based on information from a third party
5 Correction and remediation within 60 days in most cases from date of discovery
Conditions of Policy cont
6 Prevent recurrence of violation
7 Repeat violations are not eligible that is violations that occurred within the past 3 years at the same facility or as part of a pattern of violations within the past 5 years at facilities owned or operated by the same company
Conditions of Policy cont
8 Certain violations are not eligible -- those that result in serious actual harm that may have presented an imminent and substantial endangerment or that violate specific terms of an administrative or judicial order or consent agreement
9 Cooperation by the disclosing entity is required
State Self Reporting Policy
Your state may have a self reporting policy similar to the federal policy
May need to notify through both EPA and your State to receive any penalty mitigation
Things you need to do Get the inspector in amp out as quickly as
possible
Keep your records neat and orderly
Ensure records are available for review bull Location of records must be known by several
people
Audit those that transport and receive your waste (HW UW E-waste amp non-haz)
Read the Inspectorrsquos Report
SQG vs LQG Paperwork RequirementsSmall Quantity Generator
bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with
local emergency authorities
bull Emergency Info posted by a phone
bull Employees must be thoroughly familiarhellip
Large Quantity Generator
bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with
local emergency authoritiesbull Contingency Plan
bull Documented RCRA Training job descriptions
bull Biennial Reportbull Waste Min Plan (Written)
Waste minimization certification for both SQGs amp LQGs
Common Violation
Item 13 Waste Codesbull Enter up to six federalstate
waste codes to describe each waste stream identified in Item 9bndash State waste codes that are
not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste
ndash No specific required order or hierarchy for state and federal waste codes
Manifests vs LDRs
Manifests and Land Disposal Restrictions are inter-connected but separate rules
40 CFR 26220 Appendix vs 2689(b)
Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005
Manifests HW Storage Limits SQGs only
40 CFR 26234(e)Allows storage of HW for 270 days when being
transported gt 200 miles an additional 90 days
40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit
LQG 90-Day Storage Limit
40 CFR 26234(b)
Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo
Exceeding the time limit is a MAJOR violation
Hospitals
Hazardous Waste Pharmaceutical Management Standards
The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities
ndash Proposed rule anticipated publication date August 2013
Hazardous Waste Pharmaceutical Management Standards
For more information
httpwwwepagovoswhazardgenerationpharmaceuticalshtm
Waste Generated at Hospitals
Using a MSDS for Waste Determinations
OSHA regs do not require manufacturers to identify constituents present in material at concentrations below
ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)
The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS
Salts and Esters not P-listed
If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated
Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products
EPA Guidance RO12155
Epinephrine Salts
P042 listing (Epinephrine) does not apply to Epinephrine salts
Most or all Epi-pens are Epinephrine salts
EPA Guidance RO14788
Using CAS Number for Waste Determinations
Formaldehyde (CAS No 50-00-0)ndash U122 when unused
If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of
formaldehyde when disposed of amp = U122
EPA Guidance RO13658
Silver Recovery Units
Low Level Mixed Waste - LLMW
Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste
Only applies to facilities with NRC permits Notification is required if conditional
exemption is claimed Read the Rule There are conditions to to
be met
Conditions for LLMW
Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N
Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste
10 Common RCRA Violations
10
Emergency Arrangements (esp Small Quantity Generators)
Arrangements with Local Authorities
26537
The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations
SQG
LQG
Arrangements with Local Authorities(40 CFR 26537)
Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams
Layout of the facilityProperties amp associated hazards of
hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes
Arrangements with Local Authorities - Hospitals
Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the
facilityndash The types of injuries or illnesses which could result
from fires explosions or releases at the facility
9
Hazardous Waste not in Containers
8
Documentation
Common ViolationsLQG
ndash Job Descriptionsndash LQG contingency plan
Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area
LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage
area(s) documented
Job Descriptions A written job description for each position
ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position
ndash Duties describe the HW responsibilities of the individual holding that position
ndash Match name(s) to current title
Container Inspection Records
The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other
factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)
SQGLQG
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
Conditions of Policy cont
6 Prevent recurrence of violation
7 Repeat violations are not eligible that is violations that occurred within the past 3 years at the same facility or as part of a pattern of violations within the past 5 years at facilities owned or operated by the same company
Conditions of Policy cont
8 Certain violations are not eligible -- those that result in serious actual harm that may have presented an imminent and substantial endangerment or that violate specific terms of an administrative or judicial order or consent agreement
9 Cooperation by the disclosing entity is required
State Self Reporting Policy
Your state may have a self reporting policy similar to the federal policy
May need to notify through both EPA and your State to receive any penalty mitigation
Things you need to do Get the inspector in amp out as quickly as
possible
Keep your records neat and orderly
Ensure records are available for review bull Location of records must be known by several
people
Audit those that transport and receive your waste (HW UW E-waste amp non-haz)
Read the Inspectorrsquos Report
SQG vs LQG Paperwork RequirementsSmall Quantity Generator
bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with
local emergency authorities
bull Emergency Info posted by a phone
bull Employees must be thoroughly familiarhellip
Large Quantity Generator
bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with
local emergency authoritiesbull Contingency Plan
bull Documented RCRA Training job descriptions
bull Biennial Reportbull Waste Min Plan (Written)
Waste minimization certification for both SQGs amp LQGs
Common Violation
Item 13 Waste Codesbull Enter up to six federalstate
waste codes to describe each waste stream identified in Item 9bndash State waste codes that are
not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste
ndash No specific required order or hierarchy for state and federal waste codes
Manifests vs LDRs
Manifests and Land Disposal Restrictions are inter-connected but separate rules
40 CFR 26220 Appendix vs 2689(b)
Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005
Manifests HW Storage Limits SQGs only
40 CFR 26234(e)Allows storage of HW for 270 days when being
transported gt 200 miles an additional 90 days
40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit
LQG 90-Day Storage Limit
40 CFR 26234(b)
Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo
Exceeding the time limit is a MAJOR violation
Hospitals
Hazardous Waste Pharmaceutical Management Standards
The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities
ndash Proposed rule anticipated publication date August 2013
Hazardous Waste Pharmaceutical Management Standards
For more information
httpwwwepagovoswhazardgenerationpharmaceuticalshtm
Waste Generated at Hospitals
Using a MSDS for Waste Determinations
OSHA regs do not require manufacturers to identify constituents present in material at concentrations below
ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)
The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS
Salts and Esters not P-listed
If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated
Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products
EPA Guidance RO12155
Epinephrine Salts
P042 listing (Epinephrine) does not apply to Epinephrine salts
Most or all Epi-pens are Epinephrine salts
EPA Guidance RO14788
Using CAS Number for Waste Determinations
Formaldehyde (CAS No 50-00-0)ndash U122 when unused
If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of
formaldehyde when disposed of amp = U122
EPA Guidance RO13658
Silver Recovery Units
Low Level Mixed Waste - LLMW
Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste
Only applies to facilities with NRC permits Notification is required if conditional
exemption is claimed Read the Rule There are conditions to to
be met
Conditions for LLMW
Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N
Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste
10 Common RCRA Violations
10
Emergency Arrangements (esp Small Quantity Generators)
Arrangements with Local Authorities
26537
The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations
SQG
LQG
Arrangements with Local Authorities(40 CFR 26537)
Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams
Layout of the facilityProperties amp associated hazards of
hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes
Arrangements with Local Authorities - Hospitals
Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the
facilityndash The types of injuries or illnesses which could result
from fires explosions or releases at the facility
9
Hazardous Waste not in Containers
8
Documentation
Common ViolationsLQG
ndash Job Descriptionsndash LQG contingency plan
Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area
LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage
area(s) documented
Job Descriptions A written job description for each position
ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position
ndash Duties describe the HW responsibilities of the individual holding that position
ndash Match name(s) to current title
Container Inspection Records
The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other
factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)
SQGLQG
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
Conditions of Policy cont
8 Certain violations are not eligible -- those that result in serious actual harm that may have presented an imminent and substantial endangerment or that violate specific terms of an administrative or judicial order or consent agreement
9 Cooperation by the disclosing entity is required
State Self Reporting Policy
Your state may have a self reporting policy similar to the federal policy
May need to notify through both EPA and your State to receive any penalty mitigation
Things you need to do Get the inspector in amp out as quickly as
possible
Keep your records neat and orderly
Ensure records are available for review bull Location of records must be known by several
people
Audit those that transport and receive your waste (HW UW E-waste amp non-haz)
Read the Inspectorrsquos Report
SQG vs LQG Paperwork RequirementsSmall Quantity Generator
bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with
local emergency authorities
bull Emergency Info posted by a phone
bull Employees must be thoroughly familiarhellip
Large Quantity Generator
bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with
local emergency authoritiesbull Contingency Plan
bull Documented RCRA Training job descriptions
bull Biennial Reportbull Waste Min Plan (Written)
Waste minimization certification for both SQGs amp LQGs
Common Violation
Item 13 Waste Codesbull Enter up to six federalstate
waste codes to describe each waste stream identified in Item 9bndash State waste codes that are
not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste
ndash No specific required order or hierarchy for state and federal waste codes
Manifests vs LDRs
Manifests and Land Disposal Restrictions are inter-connected but separate rules
40 CFR 26220 Appendix vs 2689(b)
Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005
Manifests HW Storage Limits SQGs only
40 CFR 26234(e)Allows storage of HW for 270 days when being
transported gt 200 miles an additional 90 days
40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit
LQG 90-Day Storage Limit
40 CFR 26234(b)
Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo
Exceeding the time limit is a MAJOR violation
Hospitals
Hazardous Waste Pharmaceutical Management Standards
The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities
ndash Proposed rule anticipated publication date August 2013
Hazardous Waste Pharmaceutical Management Standards
For more information
httpwwwepagovoswhazardgenerationpharmaceuticalshtm
Waste Generated at Hospitals
Using a MSDS for Waste Determinations
OSHA regs do not require manufacturers to identify constituents present in material at concentrations below
ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)
The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS
Salts and Esters not P-listed
If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated
Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products
EPA Guidance RO12155
Epinephrine Salts
P042 listing (Epinephrine) does not apply to Epinephrine salts
Most or all Epi-pens are Epinephrine salts
EPA Guidance RO14788
Using CAS Number for Waste Determinations
Formaldehyde (CAS No 50-00-0)ndash U122 when unused
If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of
formaldehyde when disposed of amp = U122
EPA Guidance RO13658
Silver Recovery Units
Low Level Mixed Waste - LLMW
Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste
Only applies to facilities with NRC permits Notification is required if conditional
exemption is claimed Read the Rule There are conditions to to
be met
Conditions for LLMW
Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N
Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste
10 Common RCRA Violations
10
Emergency Arrangements (esp Small Quantity Generators)
Arrangements with Local Authorities
26537
The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations
SQG
LQG
Arrangements with Local Authorities(40 CFR 26537)
Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams
Layout of the facilityProperties amp associated hazards of
hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes
Arrangements with Local Authorities - Hospitals
Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the
facilityndash The types of injuries or illnesses which could result
from fires explosions or releases at the facility
9
Hazardous Waste not in Containers
8
Documentation
Common ViolationsLQG
ndash Job Descriptionsndash LQG contingency plan
Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area
LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage
area(s) documented
Job Descriptions A written job description for each position
ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position
ndash Duties describe the HW responsibilities of the individual holding that position
ndash Match name(s) to current title
Container Inspection Records
The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other
factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)
SQGLQG
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
State Self Reporting Policy
Your state may have a self reporting policy similar to the federal policy
May need to notify through both EPA and your State to receive any penalty mitigation
Things you need to do Get the inspector in amp out as quickly as
possible
Keep your records neat and orderly
Ensure records are available for review bull Location of records must be known by several
people
Audit those that transport and receive your waste (HW UW E-waste amp non-haz)
Read the Inspectorrsquos Report
SQG vs LQG Paperwork RequirementsSmall Quantity Generator
bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with
local emergency authorities
bull Emergency Info posted by a phone
bull Employees must be thoroughly familiarhellip
Large Quantity Generator
bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with
local emergency authoritiesbull Contingency Plan
bull Documented RCRA Training job descriptions
bull Biennial Reportbull Waste Min Plan (Written)
Waste minimization certification for both SQGs amp LQGs
Common Violation
Item 13 Waste Codesbull Enter up to six federalstate
waste codes to describe each waste stream identified in Item 9bndash State waste codes that are
not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste
ndash No specific required order or hierarchy for state and federal waste codes
Manifests vs LDRs
Manifests and Land Disposal Restrictions are inter-connected but separate rules
40 CFR 26220 Appendix vs 2689(b)
Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005
Manifests HW Storage Limits SQGs only
40 CFR 26234(e)Allows storage of HW for 270 days when being
transported gt 200 miles an additional 90 days
40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit
LQG 90-Day Storage Limit
40 CFR 26234(b)
Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo
Exceeding the time limit is a MAJOR violation
Hospitals
Hazardous Waste Pharmaceutical Management Standards
The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities
ndash Proposed rule anticipated publication date August 2013
Hazardous Waste Pharmaceutical Management Standards
For more information
httpwwwepagovoswhazardgenerationpharmaceuticalshtm
Waste Generated at Hospitals
Using a MSDS for Waste Determinations
OSHA regs do not require manufacturers to identify constituents present in material at concentrations below
ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)
The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS
Salts and Esters not P-listed
If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated
Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products
EPA Guidance RO12155
Epinephrine Salts
P042 listing (Epinephrine) does not apply to Epinephrine salts
Most or all Epi-pens are Epinephrine salts
EPA Guidance RO14788
Using CAS Number for Waste Determinations
Formaldehyde (CAS No 50-00-0)ndash U122 when unused
If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of
formaldehyde when disposed of amp = U122
EPA Guidance RO13658
Silver Recovery Units
Low Level Mixed Waste - LLMW
Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste
Only applies to facilities with NRC permits Notification is required if conditional
exemption is claimed Read the Rule There are conditions to to
be met
Conditions for LLMW
Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N
Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste
10 Common RCRA Violations
10
Emergency Arrangements (esp Small Quantity Generators)
Arrangements with Local Authorities
26537
The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations
SQG
LQG
Arrangements with Local Authorities(40 CFR 26537)
Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams
Layout of the facilityProperties amp associated hazards of
hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes
Arrangements with Local Authorities - Hospitals
Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the
facilityndash The types of injuries or illnesses which could result
from fires explosions or releases at the facility
9
Hazardous Waste not in Containers
8
Documentation
Common ViolationsLQG
ndash Job Descriptionsndash LQG contingency plan
Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area
LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage
area(s) documented
Job Descriptions A written job description for each position
ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position
ndash Duties describe the HW responsibilities of the individual holding that position
ndash Match name(s) to current title
Container Inspection Records
The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other
factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)
SQGLQG
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
Things you need to do Get the inspector in amp out as quickly as
possible
Keep your records neat and orderly
Ensure records are available for review bull Location of records must be known by several
people
Audit those that transport and receive your waste (HW UW E-waste amp non-haz)
Read the Inspectorrsquos Report
SQG vs LQG Paperwork RequirementsSmall Quantity Generator
bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with
local emergency authorities
bull Emergency Info posted by a phone
bull Employees must be thoroughly familiarhellip
Large Quantity Generator
bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with
local emergency authoritiesbull Contingency Plan
bull Documented RCRA Training job descriptions
bull Biennial Reportbull Waste Min Plan (Written)
Waste minimization certification for both SQGs amp LQGs
Common Violation
Item 13 Waste Codesbull Enter up to six federalstate
waste codes to describe each waste stream identified in Item 9bndash State waste codes that are
not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste
ndash No specific required order or hierarchy for state and federal waste codes
Manifests vs LDRs
Manifests and Land Disposal Restrictions are inter-connected but separate rules
40 CFR 26220 Appendix vs 2689(b)
Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005
Manifests HW Storage Limits SQGs only
40 CFR 26234(e)Allows storage of HW for 270 days when being
transported gt 200 miles an additional 90 days
40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit
LQG 90-Day Storage Limit
40 CFR 26234(b)
Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo
Exceeding the time limit is a MAJOR violation
Hospitals
Hazardous Waste Pharmaceutical Management Standards
The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities
ndash Proposed rule anticipated publication date August 2013
Hazardous Waste Pharmaceutical Management Standards
For more information
httpwwwepagovoswhazardgenerationpharmaceuticalshtm
Waste Generated at Hospitals
Using a MSDS for Waste Determinations
OSHA regs do not require manufacturers to identify constituents present in material at concentrations below
ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)
The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS
Salts and Esters not P-listed
If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated
Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products
EPA Guidance RO12155
Epinephrine Salts
P042 listing (Epinephrine) does not apply to Epinephrine salts
Most or all Epi-pens are Epinephrine salts
EPA Guidance RO14788
Using CAS Number for Waste Determinations
Formaldehyde (CAS No 50-00-0)ndash U122 when unused
If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of
formaldehyde when disposed of amp = U122
EPA Guidance RO13658
Silver Recovery Units
Low Level Mixed Waste - LLMW
Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste
Only applies to facilities with NRC permits Notification is required if conditional
exemption is claimed Read the Rule There are conditions to to
be met
Conditions for LLMW
Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N
Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste
10 Common RCRA Violations
10
Emergency Arrangements (esp Small Quantity Generators)
Arrangements with Local Authorities
26537
The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations
SQG
LQG
Arrangements with Local Authorities(40 CFR 26537)
Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams
Layout of the facilityProperties amp associated hazards of
hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes
Arrangements with Local Authorities - Hospitals
Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the
facilityndash The types of injuries or illnesses which could result
from fires explosions or releases at the facility
9
Hazardous Waste not in Containers
8
Documentation
Common ViolationsLQG
ndash Job Descriptionsndash LQG contingency plan
Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area
LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage
area(s) documented
Job Descriptions A written job description for each position
ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position
ndash Duties describe the HW responsibilities of the individual holding that position
ndash Match name(s) to current title
Container Inspection Records
The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other
factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)
SQGLQG
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
SQG vs LQG Paperwork RequirementsSmall Quantity Generator
bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with
local emergency authorities
bull Emergency Info posted by a phone
bull Employees must be thoroughly familiarhellip
Large Quantity Generator
bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with
local emergency authoritiesbull Contingency Plan
bull Documented RCRA Training job descriptions
bull Biennial Reportbull Waste Min Plan (Written)
Waste minimization certification for both SQGs amp LQGs
Common Violation
Item 13 Waste Codesbull Enter up to six federalstate
waste codes to describe each waste stream identified in Item 9bndash State waste codes that are
not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste
ndash No specific required order or hierarchy for state and federal waste codes
Manifests vs LDRs
Manifests and Land Disposal Restrictions are inter-connected but separate rules
40 CFR 26220 Appendix vs 2689(b)
Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005
Manifests HW Storage Limits SQGs only
40 CFR 26234(e)Allows storage of HW for 270 days when being
transported gt 200 miles an additional 90 days
40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit
LQG 90-Day Storage Limit
40 CFR 26234(b)
Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo
Exceeding the time limit is a MAJOR violation
Hospitals
Hazardous Waste Pharmaceutical Management Standards
The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities
ndash Proposed rule anticipated publication date August 2013
Hazardous Waste Pharmaceutical Management Standards
For more information
httpwwwepagovoswhazardgenerationpharmaceuticalshtm
Waste Generated at Hospitals
Using a MSDS for Waste Determinations
OSHA regs do not require manufacturers to identify constituents present in material at concentrations below
ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)
The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS
Salts and Esters not P-listed
If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated
Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products
EPA Guidance RO12155
Epinephrine Salts
P042 listing (Epinephrine) does not apply to Epinephrine salts
Most or all Epi-pens are Epinephrine salts
EPA Guidance RO14788
Using CAS Number for Waste Determinations
Formaldehyde (CAS No 50-00-0)ndash U122 when unused
If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of
formaldehyde when disposed of amp = U122
EPA Guidance RO13658
Silver Recovery Units
Low Level Mixed Waste - LLMW
Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste
Only applies to facilities with NRC permits Notification is required if conditional
exemption is claimed Read the Rule There are conditions to to
be met
Conditions for LLMW
Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N
Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste
10 Common RCRA Violations
10
Emergency Arrangements (esp Small Quantity Generators)
Arrangements with Local Authorities
26537
The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations
SQG
LQG
Arrangements with Local Authorities(40 CFR 26537)
Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams
Layout of the facilityProperties amp associated hazards of
hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes
Arrangements with Local Authorities - Hospitals
Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the
facilityndash The types of injuries or illnesses which could result
from fires explosions or releases at the facility
9
Hazardous Waste not in Containers
8
Documentation
Common ViolationsLQG
ndash Job Descriptionsndash LQG contingency plan
Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area
LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage
area(s) documented
Job Descriptions A written job description for each position
ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position
ndash Duties describe the HW responsibilities of the individual holding that position
ndash Match name(s) to current title
Container Inspection Records
The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other
factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)
SQGLQG
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
Waste minimization certification for both SQGs amp LQGs
Common Violation
Item 13 Waste Codesbull Enter up to six federalstate
waste codes to describe each waste stream identified in Item 9bndash State waste codes that are
not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste
ndash No specific required order or hierarchy for state and federal waste codes
Manifests vs LDRs
Manifests and Land Disposal Restrictions are inter-connected but separate rules
40 CFR 26220 Appendix vs 2689(b)
Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005
Manifests HW Storage Limits SQGs only
40 CFR 26234(e)Allows storage of HW for 270 days when being
transported gt 200 miles an additional 90 days
40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit
LQG 90-Day Storage Limit
40 CFR 26234(b)
Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo
Exceeding the time limit is a MAJOR violation
Hospitals
Hazardous Waste Pharmaceutical Management Standards
The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities
ndash Proposed rule anticipated publication date August 2013
Hazardous Waste Pharmaceutical Management Standards
For more information
httpwwwepagovoswhazardgenerationpharmaceuticalshtm
Waste Generated at Hospitals
Using a MSDS for Waste Determinations
OSHA regs do not require manufacturers to identify constituents present in material at concentrations below
ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)
The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS
Salts and Esters not P-listed
If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated
Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products
EPA Guidance RO12155
Epinephrine Salts
P042 listing (Epinephrine) does not apply to Epinephrine salts
Most or all Epi-pens are Epinephrine salts
EPA Guidance RO14788
Using CAS Number for Waste Determinations
Formaldehyde (CAS No 50-00-0)ndash U122 when unused
If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of
formaldehyde when disposed of amp = U122
EPA Guidance RO13658
Silver Recovery Units
Low Level Mixed Waste - LLMW
Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste
Only applies to facilities with NRC permits Notification is required if conditional
exemption is claimed Read the Rule There are conditions to to
be met
Conditions for LLMW
Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N
Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste
10 Common RCRA Violations
10
Emergency Arrangements (esp Small Quantity Generators)
Arrangements with Local Authorities
26537
The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations
SQG
LQG
Arrangements with Local Authorities(40 CFR 26537)
Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams
Layout of the facilityProperties amp associated hazards of
hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes
Arrangements with Local Authorities - Hospitals
Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the
facilityndash The types of injuries or illnesses which could result
from fires explosions or releases at the facility
9
Hazardous Waste not in Containers
8
Documentation
Common ViolationsLQG
ndash Job Descriptionsndash LQG contingency plan
Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area
LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage
area(s) documented
Job Descriptions A written job description for each position
ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position
ndash Duties describe the HW responsibilities of the individual holding that position
ndash Match name(s) to current title
Container Inspection Records
The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other
factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)
SQGLQG
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
Item 13 Waste Codesbull Enter up to six federalstate
waste codes to describe each waste stream identified in Item 9bndash State waste codes that are
not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste
ndash No specific required order or hierarchy for state and federal waste codes
Manifests vs LDRs
Manifests and Land Disposal Restrictions are inter-connected but separate rules
40 CFR 26220 Appendix vs 2689(b)
Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005
Manifests HW Storage Limits SQGs only
40 CFR 26234(e)Allows storage of HW for 270 days when being
transported gt 200 miles an additional 90 days
40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit
LQG 90-Day Storage Limit
40 CFR 26234(b)
Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo
Exceeding the time limit is a MAJOR violation
Hospitals
Hazardous Waste Pharmaceutical Management Standards
The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities
ndash Proposed rule anticipated publication date August 2013
Hazardous Waste Pharmaceutical Management Standards
For more information
httpwwwepagovoswhazardgenerationpharmaceuticalshtm
Waste Generated at Hospitals
Using a MSDS for Waste Determinations
OSHA regs do not require manufacturers to identify constituents present in material at concentrations below
ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)
The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS
Salts and Esters not P-listed
If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated
Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products
EPA Guidance RO12155
Epinephrine Salts
P042 listing (Epinephrine) does not apply to Epinephrine salts
Most or all Epi-pens are Epinephrine salts
EPA Guidance RO14788
Using CAS Number for Waste Determinations
Formaldehyde (CAS No 50-00-0)ndash U122 when unused
If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of
formaldehyde when disposed of amp = U122
EPA Guidance RO13658
Silver Recovery Units
Low Level Mixed Waste - LLMW
Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste
Only applies to facilities with NRC permits Notification is required if conditional
exemption is claimed Read the Rule There are conditions to to
be met
Conditions for LLMW
Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N
Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste
10 Common RCRA Violations
10
Emergency Arrangements (esp Small Quantity Generators)
Arrangements with Local Authorities
26537
The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations
SQG
LQG
Arrangements with Local Authorities(40 CFR 26537)
Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams
Layout of the facilityProperties amp associated hazards of
hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes
Arrangements with Local Authorities - Hospitals
Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the
facilityndash The types of injuries or illnesses which could result
from fires explosions or releases at the facility
9
Hazardous Waste not in Containers
8
Documentation
Common ViolationsLQG
ndash Job Descriptionsndash LQG contingency plan
Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area
LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage
area(s) documented
Job Descriptions A written job description for each position
ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position
ndash Duties describe the HW responsibilities of the individual holding that position
ndash Match name(s) to current title
Container Inspection Records
The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other
factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)
SQGLQG
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
Manifests vs LDRs
Manifests and Land Disposal Restrictions are inter-connected but separate rules
40 CFR 26220 Appendix vs 2689(b)
Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005
Manifests HW Storage Limits SQGs only
40 CFR 26234(e)Allows storage of HW for 270 days when being
transported gt 200 miles an additional 90 days
40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit
LQG 90-Day Storage Limit
40 CFR 26234(b)
Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo
Exceeding the time limit is a MAJOR violation
Hospitals
Hazardous Waste Pharmaceutical Management Standards
The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities
ndash Proposed rule anticipated publication date August 2013
Hazardous Waste Pharmaceutical Management Standards
For more information
httpwwwepagovoswhazardgenerationpharmaceuticalshtm
Waste Generated at Hospitals
Using a MSDS for Waste Determinations
OSHA regs do not require manufacturers to identify constituents present in material at concentrations below
ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)
The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS
Salts and Esters not P-listed
If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated
Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products
EPA Guidance RO12155
Epinephrine Salts
P042 listing (Epinephrine) does not apply to Epinephrine salts
Most or all Epi-pens are Epinephrine salts
EPA Guidance RO14788
Using CAS Number for Waste Determinations
Formaldehyde (CAS No 50-00-0)ndash U122 when unused
If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of
formaldehyde when disposed of amp = U122
EPA Guidance RO13658
Silver Recovery Units
Low Level Mixed Waste - LLMW
Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste
Only applies to facilities with NRC permits Notification is required if conditional
exemption is claimed Read the Rule There are conditions to to
be met
Conditions for LLMW
Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N
Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste
10 Common RCRA Violations
10
Emergency Arrangements (esp Small Quantity Generators)
Arrangements with Local Authorities
26537
The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations
SQG
LQG
Arrangements with Local Authorities(40 CFR 26537)
Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams
Layout of the facilityProperties amp associated hazards of
hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes
Arrangements with Local Authorities - Hospitals
Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the
facilityndash The types of injuries or illnesses which could result
from fires explosions or releases at the facility
9
Hazardous Waste not in Containers
8
Documentation
Common ViolationsLQG
ndash Job Descriptionsndash LQG contingency plan
Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area
LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage
area(s) documented
Job Descriptions A written job description for each position
ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position
ndash Duties describe the HW responsibilities of the individual holding that position
ndash Match name(s) to current title
Container Inspection Records
The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other
factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)
SQGLQG
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
Manifests HW Storage Limits SQGs only
40 CFR 26234(e)Allows storage of HW for 270 days when being
transported gt 200 miles an additional 90 days
40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit
LQG 90-Day Storage Limit
40 CFR 26234(b)
Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo
Exceeding the time limit is a MAJOR violation
Hospitals
Hazardous Waste Pharmaceutical Management Standards
The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities
ndash Proposed rule anticipated publication date August 2013
Hazardous Waste Pharmaceutical Management Standards
For more information
httpwwwepagovoswhazardgenerationpharmaceuticalshtm
Waste Generated at Hospitals
Using a MSDS for Waste Determinations
OSHA regs do not require manufacturers to identify constituents present in material at concentrations below
ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)
The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS
Salts and Esters not P-listed
If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated
Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products
EPA Guidance RO12155
Epinephrine Salts
P042 listing (Epinephrine) does not apply to Epinephrine salts
Most or all Epi-pens are Epinephrine salts
EPA Guidance RO14788
Using CAS Number for Waste Determinations
Formaldehyde (CAS No 50-00-0)ndash U122 when unused
If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of
formaldehyde when disposed of amp = U122
EPA Guidance RO13658
Silver Recovery Units
Low Level Mixed Waste - LLMW
Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste
Only applies to facilities with NRC permits Notification is required if conditional
exemption is claimed Read the Rule There are conditions to to
be met
Conditions for LLMW
Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N
Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste
10 Common RCRA Violations
10
Emergency Arrangements (esp Small Quantity Generators)
Arrangements with Local Authorities
26537
The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations
SQG
LQG
Arrangements with Local Authorities(40 CFR 26537)
Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams
Layout of the facilityProperties amp associated hazards of
hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes
Arrangements with Local Authorities - Hospitals
Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the
facilityndash The types of injuries or illnesses which could result
from fires explosions or releases at the facility
9
Hazardous Waste not in Containers
8
Documentation
Common ViolationsLQG
ndash Job Descriptionsndash LQG contingency plan
Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area
LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage
area(s) documented
Job Descriptions A written job description for each position
ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position
ndash Duties describe the HW responsibilities of the individual holding that position
ndash Match name(s) to current title
Container Inspection Records
The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other
factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)
SQGLQG
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
LQG 90-Day Storage Limit
40 CFR 26234(b)
Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo
Exceeding the time limit is a MAJOR violation
Hospitals
Hazardous Waste Pharmaceutical Management Standards
The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities
ndash Proposed rule anticipated publication date August 2013
Hazardous Waste Pharmaceutical Management Standards
For more information
httpwwwepagovoswhazardgenerationpharmaceuticalshtm
Waste Generated at Hospitals
Using a MSDS for Waste Determinations
OSHA regs do not require manufacturers to identify constituents present in material at concentrations below
ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)
The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS
Salts and Esters not P-listed
If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated
Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products
EPA Guidance RO12155
Epinephrine Salts
P042 listing (Epinephrine) does not apply to Epinephrine salts
Most or all Epi-pens are Epinephrine salts
EPA Guidance RO14788
Using CAS Number for Waste Determinations
Formaldehyde (CAS No 50-00-0)ndash U122 when unused
If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of
formaldehyde when disposed of amp = U122
EPA Guidance RO13658
Silver Recovery Units
Low Level Mixed Waste - LLMW
Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste
Only applies to facilities with NRC permits Notification is required if conditional
exemption is claimed Read the Rule There are conditions to to
be met
Conditions for LLMW
Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N
Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste
10 Common RCRA Violations
10
Emergency Arrangements (esp Small Quantity Generators)
Arrangements with Local Authorities
26537
The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations
SQG
LQG
Arrangements with Local Authorities(40 CFR 26537)
Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams
Layout of the facilityProperties amp associated hazards of
hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes
Arrangements with Local Authorities - Hospitals
Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the
facilityndash The types of injuries or illnesses which could result
from fires explosions or releases at the facility
9
Hazardous Waste not in Containers
8
Documentation
Common ViolationsLQG
ndash Job Descriptionsndash LQG contingency plan
Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area
LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage
area(s) documented
Job Descriptions A written job description for each position
ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position
ndash Duties describe the HW responsibilities of the individual holding that position
ndash Match name(s) to current title
Container Inspection Records
The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other
factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)
SQGLQG
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
Hospitals
Hazardous Waste Pharmaceutical Management Standards
The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities
ndash Proposed rule anticipated publication date August 2013
Hazardous Waste Pharmaceutical Management Standards
For more information
httpwwwepagovoswhazardgenerationpharmaceuticalshtm
Waste Generated at Hospitals
Using a MSDS for Waste Determinations
OSHA regs do not require manufacturers to identify constituents present in material at concentrations below
ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)
The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS
Salts and Esters not P-listed
If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated
Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products
EPA Guidance RO12155
Epinephrine Salts
P042 listing (Epinephrine) does not apply to Epinephrine salts
Most or all Epi-pens are Epinephrine salts
EPA Guidance RO14788
Using CAS Number for Waste Determinations
Formaldehyde (CAS No 50-00-0)ndash U122 when unused
If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of
formaldehyde when disposed of amp = U122
EPA Guidance RO13658
Silver Recovery Units
Low Level Mixed Waste - LLMW
Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste
Only applies to facilities with NRC permits Notification is required if conditional
exemption is claimed Read the Rule There are conditions to to
be met
Conditions for LLMW
Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N
Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste
10 Common RCRA Violations
10
Emergency Arrangements (esp Small Quantity Generators)
Arrangements with Local Authorities
26537
The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations
SQG
LQG
Arrangements with Local Authorities(40 CFR 26537)
Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams
Layout of the facilityProperties amp associated hazards of
hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes
Arrangements with Local Authorities - Hospitals
Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the
facilityndash The types of injuries or illnesses which could result
from fires explosions or releases at the facility
9
Hazardous Waste not in Containers
8
Documentation
Common ViolationsLQG
ndash Job Descriptionsndash LQG contingency plan
Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area
LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage
area(s) documented
Job Descriptions A written job description for each position
ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position
ndash Duties describe the HW responsibilities of the individual holding that position
ndash Match name(s) to current title
Container Inspection Records
The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other
factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)
SQGLQG
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
Hazardous Waste Pharmaceutical Management Standards
The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities
ndash Proposed rule anticipated publication date August 2013
Hazardous Waste Pharmaceutical Management Standards
For more information
httpwwwepagovoswhazardgenerationpharmaceuticalshtm
Waste Generated at Hospitals
Using a MSDS for Waste Determinations
OSHA regs do not require manufacturers to identify constituents present in material at concentrations below
ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)
The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS
Salts and Esters not P-listed
If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated
Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products
EPA Guidance RO12155
Epinephrine Salts
P042 listing (Epinephrine) does not apply to Epinephrine salts
Most or all Epi-pens are Epinephrine salts
EPA Guidance RO14788
Using CAS Number for Waste Determinations
Formaldehyde (CAS No 50-00-0)ndash U122 when unused
If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of
formaldehyde when disposed of amp = U122
EPA Guidance RO13658
Silver Recovery Units
Low Level Mixed Waste - LLMW
Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste
Only applies to facilities with NRC permits Notification is required if conditional
exemption is claimed Read the Rule There are conditions to to
be met
Conditions for LLMW
Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N
Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste
10 Common RCRA Violations
10
Emergency Arrangements (esp Small Quantity Generators)
Arrangements with Local Authorities
26537
The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations
SQG
LQG
Arrangements with Local Authorities(40 CFR 26537)
Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams
Layout of the facilityProperties amp associated hazards of
hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes
Arrangements with Local Authorities - Hospitals
Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the
facilityndash The types of injuries or illnesses which could result
from fires explosions or releases at the facility
9
Hazardous Waste not in Containers
8
Documentation
Common ViolationsLQG
ndash Job Descriptionsndash LQG contingency plan
Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area
LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage
area(s) documented
Job Descriptions A written job description for each position
ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position
ndash Duties describe the HW responsibilities of the individual holding that position
ndash Match name(s) to current title
Container Inspection Records
The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other
factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)
SQGLQG
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
Hazardous Waste Pharmaceutical Management Standards
For more information
httpwwwepagovoswhazardgenerationpharmaceuticalshtm
Waste Generated at Hospitals
Using a MSDS for Waste Determinations
OSHA regs do not require manufacturers to identify constituents present in material at concentrations below
ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)
The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS
Salts and Esters not P-listed
If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated
Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products
EPA Guidance RO12155
Epinephrine Salts
P042 listing (Epinephrine) does not apply to Epinephrine salts
Most or all Epi-pens are Epinephrine salts
EPA Guidance RO14788
Using CAS Number for Waste Determinations
Formaldehyde (CAS No 50-00-0)ndash U122 when unused
If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of
formaldehyde when disposed of amp = U122
EPA Guidance RO13658
Silver Recovery Units
Low Level Mixed Waste - LLMW
Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste
Only applies to facilities with NRC permits Notification is required if conditional
exemption is claimed Read the Rule There are conditions to to
be met
Conditions for LLMW
Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N
Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste
10 Common RCRA Violations
10
Emergency Arrangements (esp Small Quantity Generators)
Arrangements with Local Authorities
26537
The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations
SQG
LQG
Arrangements with Local Authorities(40 CFR 26537)
Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams
Layout of the facilityProperties amp associated hazards of
hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes
Arrangements with Local Authorities - Hospitals
Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the
facilityndash The types of injuries or illnesses which could result
from fires explosions or releases at the facility
9
Hazardous Waste not in Containers
8
Documentation
Common ViolationsLQG
ndash Job Descriptionsndash LQG contingency plan
Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area
LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage
area(s) documented
Job Descriptions A written job description for each position
ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position
ndash Duties describe the HW responsibilities of the individual holding that position
ndash Match name(s) to current title
Container Inspection Records
The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other
factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)
SQGLQG
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
Waste Generated at Hospitals
Using a MSDS for Waste Determinations
OSHA regs do not require manufacturers to identify constituents present in material at concentrations below
ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)
The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS
Salts and Esters not P-listed
If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated
Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products
EPA Guidance RO12155
Epinephrine Salts
P042 listing (Epinephrine) does not apply to Epinephrine salts
Most or all Epi-pens are Epinephrine salts
EPA Guidance RO14788
Using CAS Number for Waste Determinations
Formaldehyde (CAS No 50-00-0)ndash U122 when unused
If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of
formaldehyde when disposed of amp = U122
EPA Guidance RO13658
Silver Recovery Units
Low Level Mixed Waste - LLMW
Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste
Only applies to facilities with NRC permits Notification is required if conditional
exemption is claimed Read the Rule There are conditions to to
be met
Conditions for LLMW
Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N
Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste
10 Common RCRA Violations
10
Emergency Arrangements (esp Small Quantity Generators)
Arrangements with Local Authorities
26537
The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations
SQG
LQG
Arrangements with Local Authorities(40 CFR 26537)
Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams
Layout of the facilityProperties amp associated hazards of
hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes
Arrangements with Local Authorities - Hospitals
Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the
facilityndash The types of injuries or illnesses which could result
from fires explosions or releases at the facility
9
Hazardous Waste not in Containers
8
Documentation
Common ViolationsLQG
ndash Job Descriptionsndash LQG contingency plan
Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area
LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage
area(s) documented
Job Descriptions A written job description for each position
ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position
ndash Duties describe the HW responsibilities of the individual holding that position
ndash Match name(s) to current title
Container Inspection Records
The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other
factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)
SQGLQG
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
Using a MSDS for Waste Determinations
OSHA regs do not require manufacturers to identify constituents present in material at concentrations below
ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)
The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS
Salts and Esters not P-listed
If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated
Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products
EPA Guidance RO12155
Epinephrine Salts
P042 listing (Epinephrine) does not apply to Epinephrine salts
Most or all Epi-pens are Epinephrine salts
EPA Guidance RO14788
Using CAS Number for Waste Determinations
Formaldehyde (CAS No 50-00-0)ndash U122 when unused
If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of
formaldehyde when disposed of amp = U122
EPA Guidance RO13658
Silver Recovery Units
Low Level Mixed Waste - LLMW
Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste
Only applies to facilities with NRC permits Notification is required if conditional
exemption is claimed Read the Rule There are conditions to to
be met
Conditions for LLMW
Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N
Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste
10 Common RCRA Violations
10
Emergency Arrangements (esp Small Quantity Generators)
Arrangements with Local Authorities
26537
The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations
SQG
LQG
Arrangements with Local Authorities(40 CFR 26537)
Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams
Layout of the facilityProperties amp associated hazards of
hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes
Arrangements with Local Authorities - Hospitals
Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the
facilityndash The types of injuries or illnesses which could result
from fires explosions or releases at the facility
9
Hazardous Waste not in Containers
8
Documentation
Common ViolationsLQG
ndash Job Descriptionsndash LQG contingency plan
Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area
LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage
area(s) documented
Job Descriptions A written job description for each position
ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position
ndash Duties describe the HW responsibilities of the individual holding that position
ndash Match name(s) to current title
Container Inspection Records
The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other
factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)
SQGLQG
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
Salts and Esters not P-listed
If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated
Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products
EPA Guidance RO12155
Epinephrine Salts
P042 listing (Epinephrine) does not apply to Epinephrine salts
Most or all Epi-pens are Epinephrine salts
EPA Guidance RO14788
Using CAS Number for Waste Determinations
Formaldehyde (CAS No 50-00-0)ndash U122 when unused
If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of
formaldehyde when disposed of amp = U122
EPA Guidance RO13658
Silver Recovery Units
Low Level Mixed Waste - LLMW
Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste
Only applies to facilities with NRC permits Notification is required if conditional
exemption is claimed Read the Rule There are conditions to to
be met
Conditions for LLMW
Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N
Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste
10 Common RCRA Violations
10
Emergency Arrangements (esp Small Quantity Generators)
Arrangements with Local Authorities
26537
The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations
SQG
LQG
Arrangements with Local Authorities(40 CFR 26537)
Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams
Layout of the facilityProperties amp associated hazards of
hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes
Arrangements with Local Authorities - Hospitals
Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the
facilityndash The types of injuries or illnesses which could result
from fires explosions or releases at the facility
9
Hazardous Waste not in Containers
8
Documentation
Common ViolationsLQG
ndash Job Descriptionsndash LQG contingency plan
Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area
LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage
area(s) documented
Job Descriptions A written job description for each position
ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position
ndash Duties describe the HW responsibilities of the individual holding that position
ndash Match name(s) to current title
Container Inspection Records
The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other
factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)
SQGLQG
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
Epinephrine Salts
P042 listing (Epinephrine) does not apply to Epinephrine salts
Most or all Epi-pens are Epinephrine salts
EPA Guidance RO14788
Using CAS Number for Waste Determinations
Formaldehyde (CAS No 50-00-0)ndash U122 when unused
If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of
formaldehyde when disposed of amp = U122
EPA Guidance RO13658
Silver Recovery Units
Low Level Mixed Waste - LLMW
Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste
Only applies to facilities with NRC permits Notification is required if conditional
exemption is claimed Read the Rule There are conditions to to
be met
Conditions for LLMW
Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N
Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste
10 Common RCRA Violations
10
Emergency Arrangements (esp Small Quantity Generators)
Arrangements with Local Authorities
26537
The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations
SQG
LQG
Arrangements with Local Authorities(40 CFR 26537)
Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams
Layout of the facilityProperties amp associated hazards of
hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes
Arrangements with Local Authorities - Hospitals
Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the
facilityndash The types of injuries or illnesses which could result
from fires explosions or releases at the facility
9
Hazardous Waste not in Containers
8
Documentation
Common ViolationsLQG
ndash Job Descriptionsndash LQG contingency plan
Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area
LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage
area(s) documented
Job Descriptions A written job description for each position
ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position
ndash Duties describe the HW responsibilities of the individual holding that position
ndash Match name(s) to current title
Container Inspection Records
The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other
factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)
SQGLQG
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
Using CAS Number for Waste Determinations
Formaldehyde (CAS No 50-00-0)ndash U122 when unused
If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of
formaldehyde when disposed of amp = U122
EPA Guidance RO13658
Silver Recovery Units
Low Level Mixed Waste - LLMW
Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste
Only applies to facilities with NRC permits Notification is required if conditional
exemption is claimed Read the Rule There are conditions to to
be met
Conditions for LLMW
Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N
Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste
10 Common RCRA Violations
10
Emergency Arrangements (esp Small Quantity Generators)
Arrangements with Local Authorities
26537
The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations
SQG
LQG
Arrangements with Local Authorities(40 CFR 26537)
Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams
Layout of the facilityProperties amp associated hazards of
hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes
Arrangements with Local Authorities - Hospitals
Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the
facilityndash The types of injuries or illnesses which could result
from fires explosions or releases at the facility
9
Hazardous Waste not in Containers
8
Documentation
Common ViolationsLQG
ndash Job Descriptionsndash LQG contingency plan
Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area
LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage
area(s) documented
Job Descriptions A written job description for each position
ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position
ndash Duties describe the HW responsibilities of the individual holding that position
ndash Match name(s) to current title
Container Inspection Records
The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other
factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)
SQGLQG
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
Silver Recovery Units
Low Level Mixed Waste - LLMW
Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste
Only applies to facilities with NRC permits Notification is required if conditional
exemption is claimed Read the Rule There are conditions to to
be met
Conditions for LLMW
Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N
Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste
10 Common RCRA Violations
10
Emergency Arrangements (esp Small Quantity Generators)
Arrangements with Local Authorities
26537
The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations
SQG
LQG
Arrangements with Local Authorities(40 CFR 26537)
Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams
Layout of the facilityProperties amp associated hazards of
hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes
Arrangements with Local Authorities - Hospitals
Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the
facilityndash The types of injuries or illnesses which could result
from fires explosions or releases at the facility
9
Hazardous Waste not in Containers
8
Documentation
Common ViolationsLQG
ndash Job Descriptionsndash LQG contingency plan
Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area
LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage
area(s) documented
Job Descriptions A written job description for each position
ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position
ndash Duties describe the HW responsibilities of the individual holding that position
ndash Match name(s) to current title
Container Inspection Records
The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other
factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)
SQGLQG
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
Low Level Mixed Waste - LLMW
Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste
Only applies to facilities with NRC permits Notification is required if conditional
exemption is claimed Read the Rule There are conditions to to
be met
Conditions for LLMW
Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N
Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste
10 Common RCRA Violations
10
Emergency Arrangements (esp Small Quantity Generators)
Arrangements with Local Authorities
26537
The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations
SQG
LQG
Arrangements with Local Authorities(40 CFR 26537)
Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams
Layout of the facilityProperties amp associated hazards of
hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes
Arrangements with Local Authorities - Hospitals
Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the
facilityndash The types of injuries or illnesses which could result
from fires explosions or releases at the facility
9
Hazardous Waste not in Containers
8
Documentation
Common ViolationsLQG
ndash Job Descriptionsndash LQG contingency plan
Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area
LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage
area(s) documented
Job Descriptions A written job description for each position
ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position
ndash Duties describe the HW responsibilities of the individual holding that position
ndash Match name(s) to current title
Container Inspection Records
The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other
factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)
SQGLQG
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
Conditions for LLMW
Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N
Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste
10 Common RCRA Violations
10
Emergency Arrangements (esp Small Quantity Generators)
Arrangements with Local Authorities
26537
The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations
SQG
LQG
Arrangements with Local Authorities(40 CFR 26537)
Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams
Layout of the facilityProperties amp associated hazards of
hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes
Arrangements with Local Authorities - Hospitals
Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the
facilityndash The types of injuries or illnesses which could result
from fires explosions or releases at the facility
9
Hazardous Waste not in Containers
8
Documentation
Common ViolationsLQG
ndash Job Descriptionsndash LQG contingency plan
Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area
LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage
area(s) documented
Job Descriptions A written job description for each position
ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position
ndash Duties describe the HW responsibilities of the individual holding that position
ndash Match name(s) to current title
Container Inspection Records
The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other
factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)
SQGLQG
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste
10 Common RCRA Violations
10
Emergency Arrangements (esp Small Quantity Generators)
Arrangements with Local Authorities
26537
The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations
SQG
LQG
Arrangements with Local Authorities(40 CFR 26537)
Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams
Layout of the facilityProperties amp associated hazards of
hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes
Arrangements with Local Authorities - Hospitals
Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the
facilityndash The types of injuries or illnesses which could result
from fires explosions or releases at the facility
9
Hazardous Waste not in Containers
8
Documentation
Common ViolationsLQG
ndash Job Descriptionsndash LQG contingency plan
Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area
LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage
area(s) documented
Job Descriptions A written job description for each position
ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position
ndash Duties describe the HW responsibilities of the individual holding that position
ndash Match name(s) to current title
Container Inspection Records
The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other
factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)
SQGLQG
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
10 Common RCRA Violations
10
Emergency Arrangements (esp Small Quantity Generators)
Arrangements with Local Authorities
26537
The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations
SQG
LQG
Arrangements with Local Authorities(40 CFR 26537)
Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams
Layout of the facilityProperties amp associated hazards of
hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes
Arrangements with Local Authorities - Hospitals
Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the
facilityndash The types of injuries or illnesses which could result
from fires explosions or releases at the facility
9
Hazardous Waste not in Containers
8
Documentation
Common ViolationsLQG
ndash Job Descriptionsndash LQG contingency plan
Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area
LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage
area(s) documented
Job Descriptions A written job description for each position
ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position
ndash Duties describe the HW responsibilities of the individual holding that position
ndash Match name(s) to current title
Container Inspection Records
The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other
factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)
SQGLQG
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
10
Emergency Arrangements (esp Small Quantity Generators)
Arrangements with Local Authorities
26537
The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations
SQG
LQG
Arrangements with Local Authorities(40 CFR 26537)
Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams
Layout of the facilityProperties amp associated hazards of
hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes
Arrangements with Local Authorities - Hospitals
Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the
facilityndash The types of injuries or illnesses which could result
from fires explosions or releases at the facility
9
Hazardous Waste not in Containers
8
Documentation
Common ViolationsLQG
ndash Job Descriptionsndash LQG contingency plan
Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area
LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage
area(s) documented
Job Descriptions A written job description for each position
ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position
ndash Duties describe the HW responsibilities of the individual holding that position
ndash Match name(s) to current title
Container Inspection Records
The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other
factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)
SQGLQG
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
Arrangements with Local Authorities
26537
The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations
SQG
LQG
Arrangements with Local Authorities(40 CFR 26537)
Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams
Layout of the facilityProperties amp associated hazards of
hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes
Arrangements with Local Authorities - Hospitals
Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the
facilityndash The types of injuries or illnesses which could result
from fires explosions or releases at the facility
9
Hazardous Waste not in Containers
8
Documentation
Common ViolationsLQG
ndash Job Descriptionsndash LQG contingency plan
Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area
LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage
area(s) documented
Job Descriptions A written job description for each position
ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position
ndash Duties describe the HW responsibilities of the individual holding that position
ndash Match name(s) to current title
Container Inspection Records
The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other
factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)
SQGLQG
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
Arrangements with Local Authorities(40 CFR 26537)
Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams
Layout of the facilityProperties amp associated hazards of
hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes
Arrangements with Local Authorities - Hospitals
Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the
facilityndash The types of injuries or illnesses which could result
from fires explosions or releases at the facility
9
Hazardous Waste not in Containers
8
Documentation
Common ViolationsLQG
ndash Job Descriptionsndash LQG contingency plan
Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area
LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage
area(s) documented
Job Descriptions A written job description for each position
ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position
ndash Duties describe the HW responsibilities of the individual holding that position
ndash Match name(s) to current title
Container Inspection Records
The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other
factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)
SQGLQG
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
Arrangements with Local Authorities - Hospitals
Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the
facilityndash The types of injuries or illnesses which could result
from fires explosions or releases at the facility
9
Hazardous Waste not in Containers
8
Documentation
Common ViolationsLQG
ndash Job Descriptionsndash LQG contingency plan
Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area
LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage
area(s) documented
Job Descriptions A written job description for each position
ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position
ndash Duties describe the HW responsibilities of the individual holding that position
ndash Match name(s) to current title
Container Inspection Records
The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other
factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)
SQGLQG
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
9
Hazardous Waste not in Containers
8
Documentation
Common ViolationsLQG
ndash Job Descriptionsndash LQG contingency plan
Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area
LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage
area(s) documented
Job Descriptions A written job description for each position
ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position
ndash Duties describe the HW responsibilities of the individual holding that position
ndash Match name(s) to current title
Container Inspection Records
The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other
factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)
SQGLQG
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
8
Documentation
Common ViolationsLQG
ndash Job Descriptionsndash LQG contingency plan
Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area
LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage
area(s) documented
Job Descriptions A written job description for each position
ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position
ndash Duties describe the HW responsibilities of the individual holding that position
ndash Match name(s) to current title
Container Inspection Records
The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other
factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)
SQGLQG
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
Common ViolationsLQG
ndash Job Descriptionsndash LQG contingency plan
Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area
LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage
area(s) documented
Job Descriptions A written job description for each position
ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position
ndash Duties describe the HW responsibilities of the individual holding that position
ndash Match name(s) to current title
Container Inspection Records
The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other
factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)
SQGLQG
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
Job Descriptions A written job description for each position
ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position
ndash Duties describe the HW responsibilities of the individual holding that position
ndash Match name(s) to current title
Container Inspection Records
The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other
factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)
SQGLQG
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
Container Inspection Records
The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other
factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)
SQGLQG
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
7
Used Oil
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
6
Waste Determinations
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
Hazardous Waste Determination
Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
5 Aisle Space
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
4
Time Frames
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
Time Frames
Weekly inspections Annual RCRA training Manifests back to generator
ndash LQG after 35 days contact transporterTSDafter 45 days file exception report
ndash SQG after 60 days file ldquoexception reportrdquo
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
Also RememberRecord Retention for Training Records
Training records on current personnel must be kept until closure of the facility
Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility
3
Used Lamp Management
2
Labeling
1
Open Containers
3
Used Lamp Management
2
Labeling
1
Open Containers
2
Labeling
1
Open Containers
1
Open Containers