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…
Q&A: Is this a U-listed hazardous waste?
It all started with a telephone conversation on 09.25.20 but spread into email correspondence (which I prefer). From the telephone conversation: Person had a waste Butanol Solution recovered from a spill. SDS indicated the following: 70-80% nonionic surfactant. 5-10% n-Butyl…
Q&A: How do I manage hazardous waste during months when my generator category changes?
A question from someone who had contacted me previously (12.03.20): Hope you are doing well and enjoying the season so far 😊 I was hoping you could help me with another regulatory question regarding counting waste – or point me…
Q&A: Is my waste a non-industrial waste in Texas?
A question from a waste generator in the great state of Texas back in November of 2020: Hi, Daniel I work in a privately own Petro chemical lab. We serve the public and many big Oil companies. We test crude…
The Requirements of 40 CFR 262.16(b)(9)(ii) Post Emergency Information for Small Quantity Generator of Hazardous Waste
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…
The Requirements of 40 CFR 262.16(b)(9)(i) Emergency Coordinator for Small Quantity Generator of Hazardous Waste
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…
Q&A: Whom do I notify of the closure of my central accumulation area?
An email July 08, 2020: Subject: Closure of a CAA at LQG Message Body: Hi there – I work for a LQG facility (large quantity generator of hazardous waste) that is moving into curtailment, so not actually “closing”. We will…
Weekly Inspections of Hazardous Waste Containers in Central Accumulation Area
The regulations of the U.S. Environmental Protection Agency (USEPA) promulgated under the Resource Conservation and Recovery Act (RCRA) allow generators of hazardous waste to be exempt from many of the requirements applicable to a permitted or interim status treatment, storage,…
Q&A: Are discarded sodium-sulfur batteries eligible for a RCRA exclusion if the sodium is reclaimed for use?
A question on June 24, 2020: Daniel, I’ve come across some of your training online – quite informative – and was wondering if I could run a RCRA question past you. I have a client with some sodium-sulfur batteries that…
Signing the Hazardous Waste Manifest During COVID-19 Pandemic – UPDATED AND REVISED 08.20.20
Handlers of hazardous waste have expressed to USEPA their concern with the customer interaction required to obtain the generator’s signature on the uniform hazardous waste manifest and requested that transporters be allowed to sign the name of the generator on…