Federal regulations of the U.S. Environmental Protection Agency (USEPA) require a small quantity generator of hazardous waste (SQG) to maintain equipment and processes to prevent a hazardous waste emergency and to respond to it if one occurs. The regulations are…
A question May 04, 2018: can tclp 20 x rule be used for liquid waste or is it only for solid? My reply May 08, 2018: Thank you for contacting me. I will try to answer your question below. Neither…
Question (May 02, 2018): I have had no official training, but I have been brokering Hazardous shipment(s) for approx 25 years. I wanted to make sure that the BOL I prepared is correct. UN 3208 Metallic Substance, Water-Reactive NOS (Magnesium,…
Question received March 26, 2018: Mr Stoehr, I was doing some research when I came across your website and had a question on the requirement for a Class 9 placard on an international vessel shipment via CTU (Cargo Transport Unit,…
In an earlier article I wrote about the ban on free liquids in waste disposed of in a landfill, read: Generator Ban on Liquids in Landfills Under the Generator Improvements Rule. A ban on liquid disposal in landfills is nothing…
A question I received back on November 28, 2018: Hi Dan, I have a hazardous waste question for you. I am looking for affirmation of a conclusion that I have already come to or new awareness of some sort of…
Since its beginning, the Resource Conservation and Recovery Act (RCRA) has prohibited the landfill disposal of waste containing free liquids – with some narrowly defined exceptions per RCRA section 3004(c). The U.S. Environmental Protection Agency (USEPA) codified this prohibition as…
The Bullet: Federal facility (U.S. Navy) found to be in violation of USEPA regulations. Settlement reached with monetary penalty. Who: USEPA Region 9 Pacific Southwest Region. CONTACT: Soledad Calvino (News Media Only) / calvino.maria@epa.gov / 415-972-3512 Department of the Navy…
Here’s another example of where I ask and answer my own ‘Frequently Asked Question’. The answer is found in U.S. Environmental Protection Agency (USEPA) regulations at 40 CFR 264.314(d)(2) for permitted Treatment, Storage, and Disposal Facilities (TSDF) and §265.314(e)(2) for…
OK. Not really a ‘Frequently Asked Question’, but I asked it. The answer is found in U.S. Environmental Protection Agency (USEPA) regulations at 40 CFR 264.314(d)(1) for permitted Treatment, Storage, and Disposal Facilities (TSDF) and §265.314(e)(1) for interim status TSDFs. …
