Category: Hazardous Waste Management

What’s Happening with USTs in 2012

Secondary containment requirements for new and replaced tanks and piping Operator training requirements Periodic operation and maintenance requirements for UST systems New release prevention and detection technologies The amendments will also remove certain deferrals; update codes of practice; and update state program approval requirements to incorporate these new changes.

2011 Hazardous Waste Report Due March 1

By Elizabeth Dickinson, J.D. BLR Legal Editor Referred to by the U.S. Environmental Protection Agency (EPA) as the Hazardous Waste Report (EPA Form 8700-13 A/B), and by those in the environmental management field as the Biennial Report, the report must be submitted by March 1 of every even-numbered year with information of the facility’s hazardous […]

Universal Waste Lamps: Working Out a Recycling Program

Step 6: Create Procedures for Managing Broken Lamps The easiest way to do this is to protect lamps from breakage. Remove lamps carefully and store used lamps in a location and manner that will prevent breakage. Step 7: Decide How You’re Going to Get the Lamps to the Recycler There are several options to consider […]

Taking the Confusion Out of ‘Closed Containers’

Notwithstanding the complexity inherent in the phrase closed container, managers must be confident that they understand what must be done with the hazwaste containers at their facilities to ensure that a state or federal inspector will have no doubt that the regulations are being met. Keep in mind that containers in which hazwastes are held […]

The Controversial Contained-In Policy

One way, called the contained-in policy, attempted to smooth over the pre-existing position held by the Agency that contaminated soil that either contained a listed hazardous waste or exhibited a hazardous waste characteristic must be managed and disposed of according to all regulations governing hazardous waste (RCRA Subtitle C). Also, soil that contained listed hazardous […]

Determining Your Generator Status

Are You a LQG? If you generate 1,000 kg (about 2,200 pounds) or more of hazardous waste or more than 1 kg of acutely hazardous waste in any calendar month, you are a large quantity generator (LQG). LQGs must comply with all of EPA’s hazardous waste management rules although a partial exemption from some rules […]

Hazardous Waste Container Definitions that Stump Everyone

Containers & Tanks There’s a lot of confusion around whether a management unit is a container or a tank. Here’s the difference—you know you’re dealing with a hazardous waste container if it’s portable. A tank will always remain stationary. The RCRA hazardous waste regulations define a container as “any portable device in which a material […]

Hazardous Waste Generators FAQ Roundup

After the decision is made to vent propane from a cylinder, up until it is vented onsite, does a propane cylinder need to be managed as D001 hazardous waste? Because the container of D001 hazardous waste does not yet meet the “RCRA empty standard” (as explained at 40 CFR 261.7) the container must be managed […]

Hazardous Waste Recordkeeping Checklists for RCRA, Exporters, and Land Bans

Here’s a quick checklist of the paperwork you should have for your RCRA, hazardous waste exporting, and land ban requirements. RCRA Have you kept the following hazardous waste records for specified periods of time (if applicable)? Copies of a small quantity generator’s “reclamation agreement” for at least 3 years after the agreement’s termination or expiration […]