Practical EHS Tips, News & Advice. Updated Daily.
By: Elizabeth Dickinson, JD Are you in compliance when it comes to container management? The most common Resource Conservation and Recovery Act regulatory violations cited by state environmental regulatory agency inspectors are in connection with containers of hazardous waste. So, what are the most common mistakes in managing containers, and how can you avoid them […]
Indications of Possible Tank Issues Mr. Hoffman cited the following as indications of possible problems with USTs: • Filter clogging -Complaints of slow flow -Examine for presence of fiberglass residue/debris • Failed or erratic leak detection results -Automatic test gauging (ATG) system or statistical inventory reconciliation (SIR) test results -Perhaps intermittent • […]
DEFINITIONS FOR PURPOSES OF THE EXCLUSIONS 1) A “wipe” isa woven or non-woven shop towel, rag, pad, or swab made of wood pulp, fabric, cotton, polyester blends, or other material. 2) A “solvent-contaminated wipe” is a wipe that, after use or after cleaning up a spill: • Contains one or more of the F001 through […]
Failure to keep containers closed. Inspectors often observe hazardous waste drums that have been left open during the entire work shift, or drums with open funnels. Failure to mark the accumulation start date on the container. Generators accumulating hazardous waste on-site without a permit must be sure to clearly mark the date on which […]
The Resource Conservation and Recovery Act (RCRA), Section 3007, authorizes a representative of the U.S. EPA or a RCRA authorized state to enter any premises where hazardous waste is handled to examine records and take samples of the wastes. Similarly, the Department of Transportation (DOT) may participate where hazardous waste transporters are involved. All treatment, […]
Determining Class Monthly Volume Because volumes of hazardous waste generated are computed monthly, it is possible, for example, to be a SQG one month and a “fully regulated generator” (LQG) the next. If the amount of waste generated in a given calendar month places the generator in a larger generator class, the generator must comply […]
Of course, certain RCRA storage or “accumulation” rules must be met in order to avoid the need for a hazardous waste storage permit. Satellite accumulation is intended by EPA for industries that generate small amounts of hazardous waste in numerous locations at a facility. It allows generators to accumulate small amounts of hazardous waste until […]
Where do the candidates’ stand on EHS issues? Issue: National Environmental Policy Act By Elizabeth Dickinson, J.D. BLR Legal Editor ldickinson@blr.com Barack Obama: Supports and wants to “modernize and reinvigorate” NEPA as it provides transparency and accountability in federal decisions on the environment. The While House Council on Environmental Quality (CEQ) refers to NEPA as […]
