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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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04/24/2012

Are Compact Fluorescent Light Bulbs Hazardous Waste?

Q. Are compact fluorescent light bulbs Hazardous Waste?
 
A. Maybe. Some, but not all, compact fluorescent light bulbs (CFLs) must be managed as hazardous waste. Even those CFLs that aren’t hazardous waste may still require special handling and care.
 
Compact fluorescent light bulbs are not listed as...

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03/27/2012

Dating Hazardous Waste Containers

Q. One of the more common ways to manage hazardous waste is to temporarily accumulate hazardous waste in 55-gallon drums or other containers at or near waste-generating processes in satellite accumulation areas. Then, once the containers are full, the waste is moved to a central accumulation area for a few months before...

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02/28/2012

Hazardous Waste Labels: Industry Standards vs. Regulations

The Hazardous Waste Label: It’s an industry standard, but not actually a Federal rule.
There is no official “EPA Hazardous Waste Label.” Instead, there are a handful of requirements from both the EPA and the DOT for marking and labeling hazardous waste containers before and during shipment. There are also many non-standardized commercial labels that meet some or...

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01/23/2012

RCRA Biennial Reporting

Large quantity generators and all facilities which treat, store, or dispose of hazardous waste must file a report on their waste handling activities with the EPA (or authorized state agency) by March 1 of each even-numbered year. Small and conditionally exempt generators are excluded from...

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12/27/2011

RCRA State Authorization

Did you know that each U.S. state can enforce its own hazardous waste program and that each State program is unique and can vary from Federal standards?
 
When Congress first gave the U.S. EPA authority to regulate hazardous waste in the United States (the Resource Conservation and Recovery Act of 1976), they included provisions for...

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12/08/2011

EPA Guidance Document: How Do I Keep My RCRA Waste Containers "Closed"?

Whether it is your 90-day storage area, your 180-day storage area, or your satellite accumulation area, all containers that contain hazardous waste must remain “closed,” except when adding or removing waste [40 CFR 265.173(a)].
 
The word “closed” is...

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When US EPA introduced the Resource Conservation and Recovery Act (RCRA), the hazardous waste management standards included reduced requirements for some large-volume wastes. After studying the hazards of wastes in oil and gas exploration and production (E&P) operations, as directed by the US Congress, EPA determined regulation of these wastes under RCRA was not warranted. Therefore, many oil and gas E&P wastes are excluded from the RCRA Subtitle C hazardous waste management standards.

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Understanding the RCRA Exclusion for Oil and Gas

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