A list of 10 Resource Conservation and Recovery Act (RCRA) hazardous waste)compliance issues that could trip up businesses in the manufacturing and painting industries, hospitals, chemical processing plants and other hazardous waste generators.

1. Chuck Kroeger
April 17, 2014 | 2014 GREATER OZARKS
ENVIRONMENTAL SUMMIT
HazWaste: Ten RCRA
Compliance Issues that Can Trip
You Up

2. Waste
Determination

3. 1% = 10,000 ppm
10.0 ppm = 0.001 %

4. Employee training
Large Quantity Generator
Requires formal training plan
―ensures the facility's compliance with the requirements‖ 40 CFR 265

5. Personnel Training Content
• Hazardous waste management procedures
• (i) Procedures for using, inspecting, repairing, and replacing facility
emergency and monitoring equipment;
• (ii) Key parameters for automatic waste feed cut-off systems;
• (iii) Communications or alarm systems;
• (iv) Response to fires or explosions;
• (v) Response to ground-water contamination incidents; and
• (vi) Shutdown of operations.

6. Personnel Training
• Must be trained within 6 months of employment or new position
• Must not work unsupervised
until trained
• Annual review

7. Personnel Training Documentation
• (1) The job title for each position at the facility related to hazardous
waste management, and the name
• (2) A written job description - must include the requisite
skill, education, or other qualifications, and duties of facility personnel
assigned to each position;
• (3) A written description of the type and amount of both introductory
and continuing training
• (4) Records that document that the training or job experience has
been given to, and completed by, facility personnel.
• If all not documented - in violation

8. Employee training
Small Quantity
Generator
Ensure employees familiar with
waste handling and spill
procedures

9. Ignitable waste
stored within 50’ of
the property line
Large Quantity Generator
Requirement

10. Storage of
incompatible waste
Appendix V 40 CFR 265
Fuming drum

11. 40 CFR Appendix V

12. Storage of
incompatible waste
Spent acids/spent
corrosives
Oxidizers/acids
Alcohols/strong acids

13. Aisle space
Unobstructed movement of:
• personnel
• fire protection equipment
• spill control equipment
• decontamination equipment

14. Inspect Containers
At least Weekly

15. Inspections -
• Areas where containers are stored
• Look for leaking containers and for deterioration of containers
• Containers in good condition –
─ Not dented – raised support band
─ Not creased
─ Not severely rusted

16. Post emergency
information near phone
SQG requirement
•
Name and contact information for
emergency coordinator
• Location of fire extinguishers and
spill control equipment
• Emergency phone numbers - 911

17. Waste minimization
LQG – program in place
SQG – Good faith effort
40 CFR 262.27 Waste minimization certification

18. Waste Minimization
Solid Waste Disposal Act - the manifest is required to contain a
certification by the generator that —
(1) the generator of the hazardous waste has a program in
place to reduce the volume or quantity and toxicity of such
waste to the degree determined by the generator to be economically
practicable; and
(2) the proposed method of treatment, storage, or disposal
is that practicable method currently available to the generator
which minimizes the present and future threat to human
health and the environment.

19. Fine print on Manifest
• I certify that the waste minimization statement identified in 40 CFR
262.27(a) (if I am a large quantity generator) or (b) (if I am a small
quantity generator) is true

20. Here’s what 40 CFR 262.27 says
• (a) ―I am a large quantity generator. I have a program in place to
reduce the volume and toxicity of waste generated to the degree I
have determined to be economically practicable and I have selected
the practicable method of treatment, storage, or disposal currently
available to me which minimizes the present and future threat to
human health and the environment;‖ or
• (b) ―I am a small quantity generator. I have made a good faith effort to
minimize my waste generation and select the best waste
management method that is available to me and that I can afford.‖

21. Notification of
Hazardous Waste
Activity
form update
5.262(2)(A)3.B

22. Orphan waste
• Cabinets
• Stairwells
• Lofts

23. The Short Story – Pay attention to the details and Be Happy

24. Contact
• Chuck Kroeger, Environmental Scientist
• (417) 831-7900
• (417) 343-9335
• ckroeger@geoengineers.com