Does your facility have a fully compliant environmental program? Are you prepared for your next EPA audit? In this session, you will receive a comprehensive overview of the EPA and the components needed to create a compliant environmental program for your workplace. We will cover environmental compliance in both laboratory and manufacturing settings.

1. Ensuring an EPA-Compliant
Workplace

2. Speaker Profile
• Packaged/transported hazardous waste for Triumvirate
Environmental
• Managed Triumvirate’s Treatment, Storage, and Disposal
Facility in Astoria, Queens.
• Internal EH&S Manager for Triumvirate-New York
• Currently director of EH&S Consulting department
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3. EPA/DEP Inspection Plan
• Are you ready for a know at your door?
• Develop an EPA and/or DEP inspection
plan now.
• Train employees on their roles and
responsibilities during an environmental
inspection.
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4. First Arrival
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• Do you know where they are likely to
arrive?
▪ If so, do staff in the area know the right
people to notify?
• Designate a single point of contact.
▪ *Designate a “doer”/”runner” and even a
third person if you can.
• Attempt to understand their plan for
the day; push for a pre-meeting if
possible.

5. Generator Status?
• The generator status of your facility will
determine what regulations the inspector is
able to enforce.
▪ It is NOT an ideal situation to believe you are a
different size generator than the inspector
believes.
▪ If you are a VSQG: You are unfortunately not
safe from an environmental inspection.
- Is your hazardous waste identified?
- Do you have less than 2.2 pounds of P-coded waste
and less than 2,200 pounds of other HW onsite?
- Does the waste go to a permitted facility?
- You may still be a small quantity handler of universal
waste.
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6. Facility Walkthrough
• Satellite Accumulation Areas
▪ Closed containers? Funnels?
▪ Labeled with “hazardous waste” and symbols or words that
communicate the hazard?
▪ Containers are in good condition?
▪ Are incompatible wastes segregated? (acids and bases, solvents and
oxidizers)
▪ <55 gallons of total HW? <1 quart of acute waste?
▪ Staff conversations (Great job for the “runner”)
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7. Hazardous Waste Determination
If you haven’t identified something as hazardous waste, how
could you comply with any of the regulations?
• Mischaracterization would lead to improper management,
transportation, and disposal.
▪ Broken bulbs? Elevator rags? Laboratory drain disposal?
▪ Recommend a waste stream characterization binder for all chemical
waste streams.
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8. Short Term Storage Area
• All containers must be dated with the date
that it entered the short term storage area.
• “Hazardous waste” and other symbols or
words that communicate the hazard?
• Enough aisle space to allow for emergency
personnel and for total inspection of the
container.
• Proper signage (No smoking, unauthorized
entry, hazardous waste)
• Incompatible chemicals must be segregated
from each other.
• Closed containers, in good condition.
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9. Short Term Storage Area
• Containers cannot have accumulated more
than 90 days for LQGs and 180 days for SQGs.
• LQGs must be 50 feet away from property line, IF storing
ignitable or reactive waste.
• Both SQGs and LQGs must post
▪ The name and telephone number of the emergency coordinator;
▪ Location of fire extinguishers and spill control material, and if present,
fire alarm; and
▪ The telephone number of the fire department, unless the facility has a
direct alarm
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10. Short Term Storage Area
• Preparedness and prevention
• Both LQGs and SQGs MUST have:
▪ Internal communication device or alarm system to summon assistance
▪ Telephone or another device immediately available to call externally
▪ Emergency equipment
▪ Water at adequate volume and pressure (sprinkler system)
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11. Universal Waste
• All containers labeled with the words
“universal waste” and the type of
universal waste inside.
• Must be closed, structurally sound,
compatible, and have no evidence of
leakage.
• Able to prove that UW has been
accumulating less than a year.
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12. Facility Walkthrough
• Don’t know the answer to a question?
▪ “Let me get back to you on that.”
• Disagree with his/her interpretation of the
regulations?
▪ Ask for regulatory citation (politely).
• If you have your second or third “helper”
available, immediately correct everything
that is possible to correct.
• Attempt to write down everything they write
down, take pictures of what they take
pictures of, etc.
• AVOID ARGUING WITH THE INSPECTOR
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13. Document Review
• In most cases, the last 3 years
of environmental documents will
be required.
• It is recommended to keep 3
years available, but retain older
documents indefinitely.
• Write down everything he or she
asks for.
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14. The UHWM
• A facility-signed copy of the manifest
must be in your possession within 45
days of the ship date. Efforts to retrieve
this copy must be made at 35 days.
• How are you tracking this?
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15. e-Manifest
• Manifests must now be uploaded digitally
by the disposal facility
• These are accessible by the generator
on RCRAInfo and can be electronically
retrieved
• It is still recommended to print out
hardcopies in the event that copies are
not retrievable
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16. The LDR
• A land disposal restriction notification must accompany all
hazardous waste shipments
▪ Required for initial shipment of waste stream (although Triumvirate
provides them for each manifest)
▪ Again…how are you tracking this? With your manifests? With your
profiles?
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17. Inspection Logs
• Weekly inspections of hazardous waste
containers (except in SAAs) are required.
• Watch out for holidays (especially the
Nov./Dec./Jan. ones)
• Don’t pencil-whip these; a few issues found
(and corrected) every now and then illustrate
that the inspections are being thoughtfully
completed.
• Have these prepped to go.
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18. Contingency Plan
• For large quantity generators only
▪ Are emergency coordinators UP-TO-DATE?
(name/numbers/address)
▪ Is there a list of all emergency equipment at
the facility, along with location, physical
description, and outline of capabilities?
▪ Major entrance/exits identified?
▪ Quick Reference Guide? Must be created
when Contingency Plan is UPDATED
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19. Training Records - LQGs
• Hazardous waste training is required within
the first 6 months, and annually thereafter.
• The following must be specifically
documented:
▪ Employee name and job title related to HW mgmt.
▪ Written job description for the job title (skills,
education, qualifications, duties)
▪ Type and amount of training the employee will
receive.
▪ A record that the training was administered.
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20. Training Records - LQGs
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21. Training Records - SQGs
• ('3') the generator must ensure
that all employees are thoroughly
familiar with proper waste
handling and emergency
procedures, relevant to their
responsibilities during normal
facility operations and
emergencies;
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22. Attempt to Make Arrangements
• LQGs and SQGs
▪ Did you attempt to make arrangements with local emergency response
providers?
▪ Where’s the documentation?
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23. Other Documents
• Are you consolidating VSQG waste at an LQG?
• Episodic generation?
• Have you sent your waste out for analysis to make a HW
determination? (ELAP certification)
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24. Document Review
• Can’t find something? Network is down? Someone
accidentally took a binder home?
• Often inspectors will allow you to provide documents after the
inspection date (by COB, next day, later this week, etc.). Make
sure to clearly ask and note what their expectation is.
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25. Other Issues (Various!)
• Biennial reporting?
• Contractors onsite? What do they do with their
waste?
• Fuel oil at your facility? Do you have an SPCC
plan? Monthly visual inspections?
• Used oil at your facility? Are all containers
labeled as “used oil”?
• Right-to-Know/Tier 2 reporting? Do you know if
you’re over thresholds?
• Toxic Release Inventory reporting? Does this
apply to you?
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26. Summary
• If possible, request a closeout meeting.
• What were your findings? What type
of follow-up should be expected? Is
there anything we can correct RIGHT
NOW?
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27. Questions?

28. THANK YOU!
Mike Maffuccio, CIH
646.256.7396 (cell)
mmaffuccio@triumvirate.com