Tag: RCRA

Don’t Rush to Get that Waste Off Your Site

Problem # 1: Have you crossed the line to hazmat offeror? You’re a hazardous waste generator and you have hired a hazardous waste transporter to pick up your waste and haul it off. You’ve checked everything off your Resource Conservation and Recovery Act (RCRA) checklist and you’re ready for the waste to be out of […]

IVAN: Big Brother Really Is Watching You

An environmental monitoring system called IVAN (Identifying Violations Affecting Neighborhoods) is an environmental justice tool available to folks in California communities for reporting environmental concerns. What is IVAN? The partnership among local, state, and federal agencies and community groups, which started in 2009, has been implemented in the Wilmington area of Los Angeles, the Imperial […]

The Inside Scoop on Vapor Intrusion

The EPA suggests that the guides be used to help identify and consider key factors related to VI assessments, risk management decisions, and mitigation. Vapor intrusion is also of particular concern to property owners, municipalities, and real estate developers, especially those involved in revitalization of a perceived brownfield. Note. While the recommendations in these guides […]

8 BMPs for Hazardous Waste Containers

Violations of container management standards are very common and cited often by agency inspectors as the most common of regulatory violations, particularly by hazardous waste generators. Anyone who handles hazardous waste should be aware that many inspectors go to hazardous waste accumulation or storage areas first when conducting an inspection. A recent example of an […]

RCRA Lessons Learned—Know Your Status!

Recap: Under the federal Resource Conservation and Recovery Act (RCRA) rules, and most state variations of the RCRA rules, there are three classes of generators: large quantity generators (LQGs), small quantity generators (SQGs), and conditionally exempt small quantity generators (CESQGs). The classes are defined by the amount of hazardous waste generated each month. If you […]

New Guidance for Chemical Facilities Calls for IST

In response, in part, to the EO, the EPA has: Issued a request for information (RFI) seeking public comment on updating its risk management program (RMP) regulation, and a notice of proposed rulemaking is being prepared.  The Agency is looking for specific feedback on whether the list of RMP-regulated substances should be modified by adding […]

Will You Be WOTUSed?

Who Gets WOTUSed? Do the waterbodies near where you want to either develop or expand meet the new definition of waters of the United States (WOTUS), requiring you to get a permit? Here are some things to consider. You Need to Get a Permit if the Water … Is currently in use, was used at […]

10 Tips for LQGs for Inspecting Hazardous Waste Tanks

LQGs are those that generate either 1,000 kilograms (kg) or more of hazardous waste or more than 1 kg of acutely hazardous waste a month. Note: 1 kg = 2.2 pounds (lb) 100 kg = 220 lb 1,000 kg = 2,200 lb What’s a Tank? Although the answer may seem fairly obvious, there has been […]

Problems You May Encounter with e-Manifests

Note: A hazardous waste manifest is the shipping paper for hazardous waste. The paper manifest travels with the hazardous waste from the point of generation, through transportation, to the final treatment, storage, and disposal facility (TSDF). Each party in the chain of shipping, including the generator, signs and keeps a manifest copy, creating a “cradle-to-grave” […]

Wash, Dry, or Toss? Best Options for Your Solvent-Contaminated Wipes

So, should you wash, dry, or toss your solvent-contaminated rags? How About Dry? We can tell you right away, don’t hang your solvent-contaminated wipes out to dry. Let’s take that one off the table. Never mind the Resource Conservation and Recovery Act (RCRA) violations you would be facing, you will also have great big headaches […]