A pdf of the DTSC news release.

More about Electro-Forming Company, Inc.’s compliance history with California Department of Toxic Substances Control

RICHMOND — A metal plating company housing large amounts of hazardous chemicals must clean up its property within 30 days, a Contra Costa County Superior Court judge ruled Tuesday.

The ruling followed a request for a temporary restraining order by the state’s Department of Toxic Substances Control to force Electro-Forming and its owners to immediately remove hazardous waste from their property on Nevin Avenue.

Department officials said they sought the court order to force compliance after repeated failings by the company.

“We have made several visits to the site,” DTSC spokeswoman Tamma Adamek said. “It was clear we are dealing with a bad actor.”

In March, investigators searched the site and discovered several problems, including cyanide drums being stored near other acids that, if mixed with cyanide, could produce a deadly gas, according to court papers.

The business is at 130 Nevin Ave., nestled among apartment buildings, single-family homes, parks and several community gardens.

The owners are identified in court papers as Marion Patigler, the estate of Gerhard Patigler, and the estate of Ingrid Patigler. The Department of Toxic Substances Control also alleged that Electro-Forming has illegally stored, treated and disposed of hazardous waste, in addition to improperly storing volatile wastes next to each other.

On Tuesday afternoon, several workers wearing masks and coveralls were seen rummaging through bins and drums at the site. A man who declined to give his name said the owner was not present and took a message.

The temporary restraining order includes strict compliance deadlines and requires Electro-Forming to immediately hire an authorized contractor to remove hazardous waste stored in various drums, containers and a 6,900-gallon “Baker tank” that Electro-Forming was allegedly using to illegally store plating waste that contains hazardous levels of cyanide and metals, according to a department news release.

If Electro-Forming fails to meet deadlines set for the removal work, the temporary restraining order also authorizes DTSC to complete the removal and recover its costs.

Richmond has beefed up its Code Enforcement Unit in recent years and even sued one of its own council members, Corky Boozé, to force him to clean up a property he runs that is littered with old cars, boats and other industrial supplies.

Boozé, who denies that his property is a public nuisance, on Wednesday slammed the city for not addressing what he called a “flagrant” violation of city codes and hazardous chemical storage at Electro-Forming, which he noted is in a residential neighborhood.

“There are real health hazards all over the city, in communities with children, and we don’t do anything about it because we spend tax dollars and staff time investigating my properties,” Boozé said.

Code Enforcement Director Tim Higares and City Manager Bill Lindsay did not respond to requests for comment.

Chad Davisson, the city’s wastewater management officer, said his inspectors confirmed that Electro-Forming had no connection to the city’s sewer line and that the city knew DTSC was investigating the site.

Contact Robert Rogers at 510-262-2726. Follow him at Twitter.com/SFBaynewsrogers.

St. Paul, Minn. – In its ongoing efforts to promote environmental compliance, the Minnesota Pollution Control Agency concluded 63 enforcement cases in 39 counties throughout Minnesota during the third quarter of 2013.

Penalties from all 63 cases totaled just over $577,000.  About 45% of that total will be spent toward the completion of two supplemental environmental projects.  Vonco V of Duluth will spend $240,000 to remove hazardous materials, demolish buildings, dispose of building materials, and conduct site-restoration activities at what could amount to about 20 blighted properties in Duluth.  The Hibbing Public Utilities Commission will spend $17,250 on improvements to its facilities to reduce dust emissions.

Imposing monetary penalties is only part of the MPCA’s enforcement process.  Agency staff continue to provide assistance, support, and information on the steps and tools necessary to achieve compliance for any company or local government that requests it.

The following is a brief summary of all 63 cases completed during the third quarter of 2013:

• Vonco V LLC/Victory & Vision Properties LLC, Duluth, for air quality and solid waste violations – $300,000 (this includes $240,000 toward a supplemental environmental project)
• Hibbing Public Utilities Commission, Hibbing, for air quality violations – $34,500 (this includes $17,250 toward a supplemental environmental project)
• Specialty Minerals, Inc., International Falls, for air quality violations – $24,000
• Minnesota Department of Transportation, Princeton, for stormwater violations – $13,750
• Vermillion Fuel, Tower, for above ground storage tank violations – $9,018
• Hoyt Lakes wastewater treatment plant, Hoyt Lakes, for water quality violations – $8,950
• St. Cloud Hospital, St. Cloud, for hazardous waste violations – $7,250
• Ferrell Co., Annandale, for above ground storage tank violations – $7,040
• Henkemeyer Demolition Landfill, Sauk Rapids, for solid waste violations – $7,000
• Chet’s Plumbing, Menahga, for individual septic treatment system violations – $6,235
• Eckert Farm Supply, Gibbon, for solid waste violations – $6,149
• Roy Winjum, dba RAW Construction Co., Faribault, for individual septic treatment system violations – $5,394
• Beaver Bay wastewater treatment plant, Beaver Bay, for water quality violations – $5,322
• Micom Corp., New Brighton, for water quality violations – $5,218
• Kurt and Beckie Kronebusch, Plainview, for air quality and solid waste violations – $5,000
• City of Rochester, Rochester, for stormwater violations – $4,800
• Geislinger and Sons, Inc., Rochester, for stormwater violations – $4,800
• Clearwater Forest LLC, South Haven, for water quality violations – $4,700
• Lyle’s Used Trucks & Truck Parts, Bemidji, for stormwater violations – $4,700
• Manion Lumber & Truss, Inc., Pillager, for water quality violations – $4,700
• Elgin Milk Service, Inc., Elgin, for hazardous waste violations – $4,300
• Houston County Airport, Caledonia, for water quality violations – $4,300
• Kockelman Construction, Canby, for solid waste violations – $4,225
• X-cel Optical Co., Sauk Rapids, for hazardous waste violations – $4,200
• Lake County Gravel Pits, Two Harbors, for water quality violations – $4,190
• ConAgra Flour Mill, Hastings, for air quality violations – $4,150
• Stier Trucking LLC, Belle Plaine, for solid and hazardous waste violations – $4,100
• Kimmes Bauer Well Drilling & Irrigation, Blooming Prairie, for water quality violations – $4,000
• American Artstone Co., New Ulm, for stormwater violations – $3,900
• Bergh’s Fabricating, Inc., Willmar, for stormwater violations – $3,900
• Jarraff Industries, St. Peter, for stormwater violations – $3,900
• Meeker County Transfer Station, Litchfield, for stormwater violations – $3,900
• Brannt-Valley Excavating, Winona, for water quality violations – $3,900
• Wausau Paper Mill LLC, Brainerd, for hazardous waste violations – $3,850
• Scott Verhelst, Canby, for solid waste violations – $3,737
• Nashwauk wastewater treatment plant, Nashwauk, for water quality violations – $3,691
• J-n-J’s Recycling, Inc., Mora, for hazardous waste violations – $3,350
• Michael Gross, dba Lacey Rentals, Inc., Brandon, S.D., for individual septic treatment system violations – $3,325
• Richard Serocki, dba Serocki Excavating, Inc., Browns Valley, for individual septic treatment system violations – $3,000
• Great Lakes Aquarium of Lake Superior, Duluth, for water quality violations – $3,000
• Dean Ristow Property Services LLC, Mora, for hazardous waste violations – $2,750
• Randy’s Auto Body & Glass, Redwood Falls, for solid and hazardous waste violations – $2,650
• Rudy Bjerga Construction, Staples, for solid waste violations – $2,640
• SMI & Hydraulics, Inc., Porter, for hazardous waste violations – $2,600
• Lee Hanson, dba Serocki Excavating, Inc., Browns Valley, for individual septic treatment system violations – $2,593
• Cirrus Design Corp., Duluth, for hazardous waste violations – $2,147
• Red Wing Cabinetry, Red Wing, for air quality violations – $1,725
• McKay Lincoln Mercury, Inc., Coon Rapids, for air quality violations – $1,687
• Pauline Brannan, Kasson, for solid waste violations – $1,625
• Affordable Pumping Service, Inc., Litchfield, for individual septic treatment system violations – $1,618
• Renetta Swanson, Dunnell, for air quality and solid waste violations – $1,300
• Kandi-Lake Excavating, Inc., Lake Lillian, for individual septic treatment system violations – $1,100
• Precision Septic Service, Alden, for asbestos violations – $1,000
• Carlson Finishers, Trimont, for feedlot violations – $1,000
• Roger Matejka Farm, Sherburn, for feedlot violations – $1,000
• Scott & Lavonne Hipp, Henderson, for solid waste violations – $1,000
• Lowell Heiderscheidt, dba Heiderscheidt Construction, Sleepy Eye, for solid waste violations – $875
• Anderson Repair, Frost, for solid waste violations – $575
• AEHC LLC, dba Suite Liv’n, Willmar, for asbestos violations – $500
• Altmann Family Pork, Inc., New Ulm, for feedlot violations – $500
• Gerald Hohlen, dba Hohlen Excavating & Sewer, Bock, for individual septic treatment system violations – $500
• Supreme Pork, Inc., Lake Benton, for feedlot violations – $500
• Bishop Excavating, Blooming Prairie, for asbestos violations – $350

That comes to a total of $371,323 combined for violations of hazardous waste and solid waste regulations, in Minnesota, in third quarter of 2013 alone.  No matter what state you conduct business, if it has an authorized hazardous waste program (and every state but Iowa, Alaska, and Puerto Rico does), then your state regulatory agency will be looking for violations like these and can issue fines of this amount or even more.  The best way to avoid any violations related to the management of solid waste or hazardous waste is to utilize a training service, like mine, to not only bring you into compliance with the training requirements of the Resource Conservation and Recovery Act (RCRA) but to teach you what you need to know about all aspects of compliance with state and Federal hazardous waste regulations.  Contact me to schedule initial and annual training for your Hazardous Waste Personnel.

A complete summary of environmental enforcement actions and news releases can be found on the MPCA’s News Media Center Web page.  For questions on specific enforcement cases, please contact Stephen Mikkelson, Information Officer at (218) 316-3887, or toll free at (800) 657-3864.

Release Date: 12/17/2013
Contact Information: Wyn Hornbuckle, U.S. Dept. of Justice, 202-514-5007, wyn.hornbuckle@usdoj.gov Mark MacIntyre, EPA Public Affairs, 206-553-7302, macintyre.mark@epa.gov

(SEATTLE – December 17, 2013) – Oregon Metallurgical of Albany, Ore. and TDY Industries of Millersburg, Ore. have agreed to pay a combined total of $825,000 in civil penalties to resolve alleged violations related to improper storage, transportation, and disposal of anhydrous magnesium chloride, a reactive hazardous waste that can pose serious fire and explosion threats. 

In addition to the penalty, the companies must improve hazardous waste management practices and upgrade recordkeeping on the hazardous wastes generated at each facility to ensure proper management and avoid potential accidents and injuries. 

The government complaint alleges that both companies improperly stored, transported and disposed of anhydrous magnesium chloride waste over a period of several years, in violation of the Resource Conservation and Recovery Act (“RCRA”) which governs the storage, disposal, and transportation of hazardous waste. EPA estimates that the companies illegally shipped approximately 160,000,000 pounds of this hazardous waste to Oregon landfills that were not equipped or permitted to dispose of untreated reactive wastes. 

The facilities produce and process titanium and zirconium, which generates large quantities of anhydrous magnesium chloride as a byproduct. Anhydrous magnesium chloride is a reactive hazardous waste regulated under RCRA. Anhydrous magnesium chloride can react violently when it comes into contact with water, producing large amounts of heat as well as hydrogen and hydrogen sulfide gas in potentially toxic and flammable quantities. 

Mining and mineral processing facilities such as these two facilities generate more toxic and hazardous waste than any other industrial sector. If not properly managed, these wastes pose a high risk to human health and the environment. EPA’s enforcement program will continue to focus on reducing risks associated with hazardous waste operations at mineral processing facilities.

Oregon Metallurgical and TDY Industries are wholly owned subsidiaries of Allegheny Technologies Inc., headquartered in Pittsburgh, Pa. 

The proposed consent decree filed on Friday, December 13, 2013 in Federal District Court for the District of Oregon is subject to a 30-day public comment period and final court approval.

Read the release here.

Wow!  $825K for violations of the RCRA regulations!  What could this facility have done to prevent this?  One thing is they could have contracted with me to provide Onsite Training.  Part of my service with Onsite Training is a walk-through of the facility the day before to prepare for the training, but also to provide guidance on regulatory compliance.  I could have assisted them with something like this.  Or, attendance at one of my Training Seminars would have provided them with the information and the tools necessary comply with the RCRA regulations.  Don’t miss my Training Seminar in Portland, OR on July 24, 2014.  Or, contact me to arrange for  Onsite Training.  Or, call me with a question, I’m glad to help you.

EPA to spend $3 Million to Address Heavy Metal Contamination

Contact Information: Brenda Reyes, 787-977-5869, reyes.brenda@epa.gov

(New York, NY – Nov. 5, 2013) The U.S. Environmental Protection Agency has finalized its plan to address contaminated soil at the Scorpio Recycling Superfund site in Toa Baja, Puerto Rico. Previous metal recycling and battery crushing activities at the site resulted in contamination of the soil with lead and other metals. Lead is a toxic metal that can cause damage to a child’s ability to learn and a range of health problems in adults. Exposure to heavy metals can cause serious health effects. Under the plan, contaminated soil from the site will be consolidated in two controlled areas and covered to reduce potential exposure to the hazardous materials.

The EPA held a public meeting on August 14, 2013 in Toa Baja to explain its proposed plan. The EPA took public comment for 30 days and considered public input before finalizing the decision.

Scorpio Recycling, Inc. was a metals recycling company that operated from 1972 until 2010. The site was added to the Superfund list in 1999 after high concentrations of heavy metals and other contaminants were found in the soil.

Under the EPA plan, contaminated soil that poses a potential risk to people’s health will be moved and consolidated in two areas of the site, a conservation area and an industrial area. Clean soil will be placed over contaminated soil in the conservation area and a gravel cover will be placed over soil in the industrial area.

Long-term monitoring will ensure that the covers prevent direct contact with underlying waste. The plan also requires new deed restrictions that will prevent activities that could disturb the covers and prohibit any future on-site residential construction. The EPA will conduct a review every five years to ensure the effectiveness of the cleanup.

The Superfund program operates on the principle that polluters should pay for the cleanups, rather than passing the costs to taxpayers. After sites are placed on the Superfund list of the most contaminated waste sites, the EPA searches for parties responsible for the contamination and holds them accountable for the costs of investigations and cleanups. In this instance, the EPA did not identify a viable party to pay the cleanup costs. The EPA estimates the cost of this cleanup will be about $3 million, which will be provided by the EPA federal Superfund program.

To view the EPA’s record of decision for the Scorpio Recycling Superfund site, please visit: http://www.epa.gov/region02/superfund/npl/scorpio/index.html

Be sure to read the first two sentences of the last paragraph of the news release.  Any person that generates a solid waste, which includes wastes that are ultimately recycled, is subject to liability under the Comprehensive Emergency Response, Compensation and Liability Act (CERCLA, or as it is better known:  Superfund).  The goal of the EPA for a property categorized as a Superfund Site is to identify any person or company that contributed to the contamination and have them pay for the clean-up.  Apparently, in this case, they were not able to identify any Potentially Responsible Parties (PRPs).  But if they did, then those PRPs would be shelling out money to the EPA and remediation contractors (not to mention lawyers) to clean-up the site.

What can you do to protect yourself?

• Minimize the amount of waste you generate:  hazardous, non-hazardous, used oil, universal waste, recycled material, etc.
• Perform audits of all waste disposal and recycling facilities to ensure they are handling your waste properly.
• Hope you get lucky.  No matter what you do, if you generate any waste for recycling or disposal, you are subject to the possibility of being identified as a PRP.  It is one of the costs of doing business in the US.

Another precautionary measure:  provide Hazardous Waste Personnel Training for any employees who work with, around, or handle hazardous waste or may respond to a hazardous waste emergency.  Please contact me for your free training consultation.

On its website the US Government Printing Office makes a wealth of Federal publications available for review and download; one of these is the Federal Register.

Published by the Office of the Federal Register, National Archives and Records Administration (NARA), the Federal Register is the official daily publication for rules, proposed rules, and notices of Federal agencies and organizations, as well as executive orders and other presidential documents.

See below for a brief summary of announcements in the Federal Register by the US EPA on the subject of Hazardous Waste and the Pipeline & Hazardous Materials Safety Administration (PHMSA) of the US DOT on the subject of Transportation of Hazardous Materials.

The Federal Register is a great way to look down the road and see potential changes to the regulations long before they are put into effect (sometimes The Rulemaking Process takes years before a final rule is issued, if ever).  Knowledge of these potential changes provides you with several advantages:

• Additional time to modify your business operations to comply.
• Awareness of on what topics the regulatory agencies intend to focus their efforts.
• The ability to register your concerns, complaints, suggestions, etc. in order to modify the proposed rule before a final rule is issued.  It can be done, really!
• Make changes to your training program to account for changes that become effective before the next training cycle.
• Alert you to the need to re-train your employees prior to their next scheduled training cycle, if necessary.
• Keep you abreast of changes to the regulations that affect your business and/or your industry group.

Please note that this is my best effort to identify the relevant announcements in the Federal Register that may be of interest to generators of hazardous waste and shippers of hazardous materials.  I encourage you to review the list of Federal Register publications yourself to ensure regulatory compliance.

October 1 through October 31, 2013

PHMSA – Hazardous Materials Regulations (HMR):

Rules and Regulations:

Clarification on Fireworks Policy Regarding Approvals or Certifications for Firework Series Pages 60763 – 60766 [FR DOC # 2013-24082] PDF | Text | More

Clarification on Fireworks Policy Regarding Approvals or Certifications for Specialty Fireworks Devices Pages 60766 – 60766 [FR DOC # 2013-24092] PDF | Text | More

Hazardous Materials Regulations: Penalty Guidelines Pages 60726 – 60745 [FR DOC # 2013-23887] PDF | Text | More

Hazardous Materials: Minor Editorial Corrections and Clarifications (RRR) Pages 60745 – 60755 [FR DOC # 2013-23873] PDF | Text | More

Hazardous Materials: Enhanced Enforcement Procedures-Resumption of Transportation Pages 60755 – 60763 [FR DOC # 2013-23894] PDF | Text | More

Hazardous Materials: Corrections and Response to Administrative Appeals (HM-215K, HM-215L, HM-218G and HM-219) Pages 65453 – 65488 [FR DOC # 2013-24714] PDF | Text | More

Proposed Rules:

None

Notices:

Information Collection Activities Pages 64049 – 64051 [FR DOC # 2013-25105] PDF | Text | More

USEPA – Resource Conservation and Recovery Act (RCRA):

Rules and Regulations:

None

Proposed Rules:

None

Notices:

None

Information can be helpful but it’s useless if you are not able to make sense of it, determine how any changes to the rules and regulations (final or proposed) will affect your operations, and communicate the necessary information to your personnel.  I can help you do that.  Please contact me for a free consultation to determine your regulatory requirements and how training can help you to attain and maintain compliance.

On its website the US Government Printing Office makes a wealth of Federal publications available for review and download; one of these is the Federal Register.

Published by the Office of the Federal Register, National Archives and Records Administration (NARA), the Federal Register is the official daily publication for rules, proposed rules, and notices of Federal agencies and organizations, as well as executive orders and other presidential documents.

See below for a brief summary of announcements in the Federal Register by the US EPA on the subject of Hazardous Waste and the Pipeline & Hazardous Materials Safety Administration (PHMSA) of the US DOT on the subject of Transportation of Hazardous Materials.

The Federal Register is a great way to look down the road and see potential changes to the regulations long before they are put into effect (sometimes The Rulemaking Process takes years before a final rule is issued, if ever).  Knowledge of these potential changes provides you with several advantages:

• Additional time to modify your business operations to comply.
• Awareness of on what topics the regulatory agencies intend to focus their efforts.
• The ability to register your concerns, complaints, suggestions, etc. in order to modify the proposed rule before a final rule is issued.  It can be done, really!
• Make changes to your training program to account for changes that become effective before the next training cycle.
• Alert you to the need to re-train your employees prior to their next scheduled training cycle, if necessary.
• Keep you abreast of changes to the regulations that affect your business and/or your industry group.

Please note that this is my best effort to identify the relevant announcements in the Federal Register that may be of interest to generators of hazardous waste and shippers of hazardous materials.  I encourage you to review the list of Federal Register publications yourself to ensure regulatory compliance.

September 1 through September 30, 2013

PHMSA – Hazardous Materials Regulations (HMR):

Rules and Regulations:

None

Proposed Rules:

Hazardous Materials: Rail Petitions and Recommendations To Improve the Safety of Railroad Tank Car Transportation (RRR) Pages 54849 – 54861 [FR DOC # 2013-21621]         PDF | Text | More

Hazardous Materials: Failure To Pay Civil Penalties Pages 58501 – 58507 [FR DOC # 2013-22952]                PDF | Text | More

Notices:

Safety Advisory: Unauthorized Marking of Compressed Gas Cylinders Pages 58604 – 58604 [FR DOC # 2013-23104]                PDF | Text | More

Safety Advisory: Unauthorized Filling of Compressed Gas Cylinders Pages 58604 – 58605 [FR DOC # 2013-23080]                PDF | Text | More

Notice of Application for Special Permits Pages 59420 – 59422 [FR DOC # 2013-23461]       PDF | Text | More

Notice of Applications for Modification of Special Permit Pages 59422 – 59422 [FR DOC # 2013-23460]       PDF | Text | More

Delayed Applications Pages 59422 – 59423 [FR DOC # 2013-23458]           PDF | Text | More

Special Permit Applications Pages 59423 – 59424 [FR DOC # 2013-23459]               PDF | Text | More

USEPA – Resource Conservation and Recovery Act (RCRA):

Rules and Regulations:

Virginia: Final Authorization of State Hazardous Waste Management Program Revisions Pages 54178 – 54182 [FR DOC # 2013-21378]        PDF | Text | More

Louisiana: Final Authorization of State-Initiated Changes and Incorporation by Reference of Approved State Hazardous Waste Management Program Pages 58890 – 58897 [FR DOC # 2013-22972]            PDF | Text | More

Proposed Rules:

Virginia: Final Authorization of State Hazardous Waste Management Program Revisions Pages 54200 – 54201 [FR DOC # 2013-21371]        PDF | Text | More

Louisiana: Final Authorization of State-initiated Changes and Incorporation by Reference of State Hazardous Waste Management Program Pages 58988 – 58988 [FR DOC # 2013-22969]         PDF | Text | More

Notices:

None

Information can be helpful but it’s useless if you are not able to make sense of it, determine how any changes to the rules and regulations (final or proposed) will affect your operations, and communicate the necessary information to your personnel.  I can help you do that.  Please contact me for a free consultation to determine your regulatory requirements and how training can help you to attain and maintain compliance.

In an earlier article I explained the requirements of the USEPA for Large and Small Quantity Generators of hazardous waste to conduct weekly inspections of hazardous waste containers.  Briefly, the USEPA, along with most states with authorized hazardous waste programs, requires an LQG or SQG to conduct inspections of areas where hazardous waste containers are stored, “At least weekly…”  Trouble is, “weekly” is not defined by USEPA or the regulations of most states (Alabama being one of the exceptions), leaving it up to the enforcing agency to interpret.  Most, in my experience, interpret “weekly” as every seven days, meaning inspections should not be completed more than seven days apart.  Alabama, however, takes a different approach. (more…)

DNREC’s Environmental Crimes Unit says it discovered drums of hazardous materials in a New Castle area warehouse.

DNREC officials say information from the U.S Environment Protection Agency’s Criminal Division led them to the warehouse rented by Recyclers of Delaware LLC.

There, according to DNREC, Environmental Crimes Unit officers found numerous unlabeled 55-gallon drums. Initial testing indicated those drums contained “volatile organic compounds and flammable chemicals.”

DNREC officials note the chemicals have been secured by its Emergency Response team and pose no threat to public health while a disposal is arranged.

Samples have been given to the EPA for further analysis. A decision on what, if any, action will be taken against Recyclers of Delaware will come after that analysis and the investigation are completed.

According to DNREC officials, the EPA’s discovery of a larger stockpile of hazardous material in Gloucester County, New Jersey yielded a link that led to the New Castle warehouse.

– See more at: http://www.wdde.org/51807-dnrec-hazardous-chemical-new-castle#sthash.B64JS9K9.dpuf

[slideshare id=27815360&doc=40cfr261-131101115151-phpapp02]

This article is the second in a series to address the requirements of 40 CFR 265, Subpart D – Contingency Plan and Emergency Procedures as it applies to a large quantity generator of hazardous waste (LQG).  Each article will explain the requirements of a specific section of Subpart D; the previous article: 40 CFR 265.50 Applicability.  Keep in mind the regulations of your state may differ from these Federal regulations.

The purpose of this article: identify and explain the requirements of 40 CFR 265.51 Purpose and Implementation of Contingency Plan.

Hold on a minute!  These regulations were revised and moved to a new location within Title 40 of the CFR by the Generator Improvements Rule.  If your state has not yet adopted the Generator Improvements Rule, then this article is still applicable to you (but it won’t be for much longer).  If your state has adopted and been authorized to enforce the Generator Improvements Rule, then these regulations no longer apply to you.  Read: What is the status of the Generator Improvements Rule in my state?

To see an explanation of these regulations as revised by the Generator Improvements Rule you must refer to the following:

• Large quantity generator of hazardous waste (LQG)
• Small quantity generator of hazardous waste (SQG)

To see an explanation of the regulations prior to the revisions of the Generator Improvements Rule, please continue reading this article. (more…)