Tag: RCRA

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 […]

USTs: 15 Steps to Take After a Flood

After a Flood If your UST has been in a flood, take the following actions, depending on site-specific conditions: Do not assume everything is OK because water didn’t actually flood over the station. The water table could have risen and caused problems. Make sure the power to any UST-related equipment is off (such as power […]

USTs: 8 Steps to Prepare for Floods

Even if you have insurance to cover repairs, bringing a damaged UST back up to code can be a lengthy process, particularly if the flooding is widespread and qualified UST contractors are in high demand. Damages could include piping connections broken by movement, compromised electrical and leak prevention/detection systems, infiltration by water, and loss of […]

4 Tips for Making Friends with EPA’s Citizen Cops

Let’s face it. If someone in your community has a complaint about your facility, you would much rather hear from them than having the EPA alerted first. It’s all about communication. We’ve discussed some of these ideas before, but some of them bear repeating. These tips can help you in developing an open relationship with […]

RCRA Violations: Lessons Learned

Civil Penalties With a few exceptions, most violations of RCRA’s hazardous waste regulations carry a civil penalty of up to $37,500 per day per violation and the possible suspension or revocation of the violator’s permit. Criminal Penalties Knowing violations of hazardous waste rules can result in fines of up to $50,000 per day per violation […]

Dings in Your NPDES Permit Shield

NPDES permits establish allowable discharge limits or effluent limitations that include both concentration and volume of flow. Section 402(k) of the federal Clean Water Act (CWA) provides for what is known as a “permit shield.” This means that if you are in compliance with your NPDES permit, you are deemed to be in compliance with […]

4 Extra Chemical Reporting Tips for Waste Facilities

The EPA claims that there are sufficient regulatory reasons for TSDFs to be in contact with local authorities concerning emergency procedures. The Agency points to 40 CFR 264.30 to 264.37 and 40 CFR 265.30 to 265.37, the requirements that TSDFs develop preparedness and prevention plans, and specifically 40 CFR 264.37 and 40 CFR 265.37, where […]

Focus on 4 to Guard against Refrigeration Leaks

Owners of equipment with charges of more than 50 pounds (lb) of refrigerant are required to repair leaks in the equipment when the leak rates exceed a certain percentage of the charge over a 12-month period. For commercial and industrial process refrigeration, the leak rate requiring repair is 35 percent or more of the charge […]