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Step 1: Assess Your Facility To do this, ask the following questions: How many fluorescent lamps are in the facility? Where are they located? How often do you change your fluorescent lamps? How many fluorescent lamps are you disposing of each month and year? How are you handling and storing the used lamps? Do all […]
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 […]
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 […]
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 […]
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 […]
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 […]
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 […]
Here are a few of the most common container violations you should be aware of: Not keeping containers closed. Inspectors often observe hazardous waste drums that have been left open during the entire work shift, or drums with open funnels. No accumulation start date is marked on the container. If you are a generator accumulating […]
Is the material a solid waste? Is the waste specifically excluded from RCRA’s hazardous waste regulation? If the waste is a solid waste, is the solid waste “hazardous”? This requires you to determine: Is the waste a “listed” hazardous waste? Does the waste exhibit one or more of the four characteristics of hazardous waste? Is […]