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03/19/2013

EPA Meeting on e-Manifest

Greetings from the Windy City. The second public meeting on the e-manifest system has just concluded at the EPA’s Region 5 headquarters in downtown Chicago. The meetings were well attended, with a lot of good discussion.
 
The president signed the Hazardous Waste Electronic Manifest Establishment Act on October 5, 2012, which provides...

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02/26/2013

Managing Hazardous Waste as Used Oil

In general, the EPA does not consider used oils to be hazardous waste. In establishing proper management standards for these wastes, the EPA presumed that recycling, from re-refining to burning as fuel, would occur. The used oil rules at 40 CFR 279 are less burdensome than the hazardous waste regulations (40 CFR 260-270). In some circumstances, the EPA even allows...

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01/29/2013

Understanding Your Generator Status

Any person who produces hazardous waste or causes hazardous waste to become subject to regulation is a generator of hazardous waste. Waste can be produced by industrial processes or through recycling and waste treatment. Wastes can become subject to regulation without actually being produced through the closure of a process or facility or the cleanup...

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11/27/2012

How to Avoid Speculative Accumulation

Recycling hazardous waste is a great way to save the planet and your bottom line. The RCRA regulations include many provisions under which hazardous wastes can be legitimately recycled scattered throughout 40 CFR Part 261, Subpart A. When you recycle hazardous waste, you are exempt from the following regulations that apply to hazardous waste...

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10/23/2012

Precious Metals Recycling

Hazardous wastes that contain economically significant amounts of precious metals are excluded from RCRA when reclaimed, regardless of their other properties. A few rules still apply. They can be found at 40 CFR 266, Subpart F.
 
The U.S. EPA considers the following materials to be “precious metals”...

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08/28/2012

Elementary Neutralization: Treatment Without a Permit

Treating your hazardous waste without a permit?! Is that really possible? Yes! Yes, it is. While the EPA generally prohibits you from treating hazardous waste without a permit, there are exceptions. Under certain conditions you can neutralize your corrosive hazardous waste and pipe it out as sewage rather than...

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07/24/2012

Frequency of Hazardous Waste Tanks Self-Inspections

Throughout Parts 264 and 265 of 40 CFR, the U.S. EPA requires persons who store hazardous waste, including large and small quantity generators, to periodically self-inspect waste containment units. These periodic self-inspections are your opportunity to ensure that you stay in compliance with RCRA and head off any...

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07/02/2012

DOT Training Requirements for Signing a Waste Manifest

“I have an employee that is responsible for signing the manifest for our off site shipments of hazardous waste. I have heard that this employee is subject to DOT training. If this is true, what training must I provide to this employee?”
 
This is a common question that is asked by compliance managers at sites dealing with...

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06/26/2012

Determining Toxicity & When to Use the TCLP Test

A solid waste exhibits the characteristic of toxicity if it contains an elevated level of a toxicity contaminant. The toxicity contaminants are listed in Table 1 at 40 CFR 261.24 and include, but are not limited to...

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05/22/2012

What Are the Underlying Hazardous Constituents the Land Disposal Restrictions Make You Treat For?

Section 3004(m) of the Resource Conservation and Recovery Act prohibits the land disposal of any hazardous waste unless it has been treated to minimize short- and long-term threats to human health and the environment. The EPA specifies waste treatment standards in 40 CFR Part 268—“Land Disposal Restrictions.” For most wastes, the treatment standard is to...

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