The title of this article contains three questions, but really they are all the same.  If you have a product that has been abandoned, then it has been discarded; and if a product has been discarded, then it is a solid waste.  Once you have determined your product is a solid waste, you must conduct a hazardous waste determination and identify its final status as a hazardous waste, non-hazardous waste, or perhaps a waste with an applicable exclusion from regulation.

A question I frequently receive at my Public Training Seminars and my Onsite Training goes something like this,

Company A has a 55-gallon drum of an unused product in storage.  The container is unopened and it is believed that the contents are still usable, however Company A has no immediate plans for use and does not know what it is going to do with the drum.  Based on the MSDS and generator knowledge the product will be a hazardous waste when disposed of.  When, if ever, must Company A begin to manage the unused product as a hazardous waste?

This is tough question because the regulations can only take you so far.  After that it is up to you as the generator of the waste to determine if the product in question is a solid waste and if so, is it a hazardous waste.  This article will review the applicable Federal regulations of the US EPA to help identify when a product becomes a waste.  It will also provide some criteria to follow when making your decision of Product v. Waste. (more…)

Except for a limited time in the past (June 24, 1989 to June 21, 1991) and within a limited range (New York, New Jersey, Connecticut, Rhode Island, and Puerto Rico) the generation, handling, transportation, and disposal of medical waste is not regulated by the US EPA under the Resource Conservation and Recovery Act (RCRA).  For more information about medical waste and RCRA read:  US EPA Regulations for the Management of Medical Waste.  With the expiration of the provisions of the Medical Waste Tracking Act of 1988, US EPA shifted responsibility for regulation of Medical Waste disposal to the individual states.

If your state is like most I am familiar with, the regulation of medical waste (sometimes also known as:  Regulated Medical Waste, Biomedical Waste, Infectious Waste, or Potentially Infectious Medical Waste) is limited to a solid or liquid waste which presents a threat of infection to humans or has come in contact with human or animal blood, tissue, fluids, excretion, etc. or devices that have come in contact with any of them.  Also – again, based on my experience – most states limited the sources of Regulated Medical Waste mostly to hospitals, dialysis clinics, dental offices, health maintenance organizations, surgical clinics, medical buildings, physicians’ offices, laboratories, veterinary clinics, funeral homes, tattoo parlors, and the like.

Not so in Florida.  This article will focus on the State of Florida’s inclusion of discarded sharps from industry, manufacturing, or other non-medical commercial entities as Biomedical Waste and what you must do as a Biomedical Waste Generator in Florida to comply with the regulations. (more…)

[slideshare id=16783628&doc=40cfr261-4a7-130226105158-phpapp01]

[slideshare id=16445667&doc=40cfr261-4a6-130209184803-phpapp02]

In a trio of earlier articles I explained the requirements of the US EPA for determining your hazardous waste generator status.

• Understanding the Requirements for Determining Your Hazardous Waste Generator Status.
• Determining Hazardous Waste Generator Status Based on Generation of Acute Hazardous Waste.
• Determining Hazardous Waste Generator Status Based on the Accumulation of Hazardous Waste.

In these articles Iwas careful to point out that the information is based solely on the Federal regulations of the US EPA.  Any State with an authorized hazardous waste program, such as Maryland, may create and enforce regulations very different from those of the US EPA, and this Maryland does.  A hazardous waste generator in Maryland therefore must ensure they are in compliance with the State of Maryland regulations otherwise known as the Code of Maryland (COMAR) in lieu of those of the US EPA found in the Code of Federal Regulations (CFR).

This article will identify and explain the regulations for determining hazardous waste generator status in Maryland.

A key distinction between the regulations of the US EPA in Title 40 of the Code of Federal Regulations (CFR) and COMAR is the difference in the recognized classifications of hazardous waste generator status.  While US EPA recognizes three hazardous waste generator status:

1. Large Quantity Generator (LQG)
2. Small Quantity Generator (SQG)
3. Conditionally Exempt Small Quantity Generator (CESQG)

Maryland only recognizes two:

1. Fully Regulated Generator – which encompasses the SQG & LQG status of the US EPA.
2. Maryland Small Quantity Generator (SQG) – which is similar to the CESQG status of the US EPA.

Maryland does not recognize the CESQG status for generators of hazardous.

Table 1 summarizes the differences in hazardous waste generator status between the US EPA and the Maryland Department of the Environment (MDE).

The requirements of COMAR Title 26, Subtitle 13, Section 02.05 for determining Small Quantity Generator status are summarized in Table 2.  In order to maintain the status of an SQG in Maryland a generator must maintain its hazardous waste at or below the levels indicated in Table 2.

Note that for most of the criteria you may equal but not exceed the threshold amount.  However, for the amount of hazardous waste generated per calendar month your hazardous waste generation must be below 100 kg/mo.

If you are able to maintain your waste generation and accumulation at or below these thresholds as applicable, you have a reduced regulatory burden as a (Maryland) SQG, which is similar to that of the Conditionally Exempt Small Quantity Generator (CESQG) of the US EPA, requirements include:

• Correctly identify all hazardous waste you generate.
• Keep on-site accumulation of hazardous waste at or below 100 kg at any one time.
• Ensure disposal of hazardous waste to a state-approved hazardous waste disposal facility.

If you exceed any of the above thresholds your status is a Fully Regulated Generator in Maryland, which is similar to the Large Quantity Generator (LQG) status of the US EPA, requirements include:

• Correctly identify all hazardous waste you generate.
• Submit a Notification of Hazardous Waste Activity form and obtain a US EPA ID Number.
• Accumulate hazardous waste in a DOT-Approved container, properly labeled and marked.
• Accumulate hazardous waste onsite for no more than the time allowed:
  • 90 days, or;
  • 180 days if the generator has ≤500 kg of hazardous waste and ≤1 kg of acute hazardous waste.
• Document offsite shipments of hazardous waste on the Uniform Hazardous Waste Manifest to a state-approved hazardous waste disposal facility.
• Fulfill the requirements for Emergency Preparedness and Prevention.
• Prepare a Contingency Plan for hazardous waste emergencies.  Submit copies to state and local agencies per MDE requirements.
• Train personnel who handle hazardous waste or who may respond to a hazardous waste emergency.
• Submit an annual report of hazardous waste activity to the MDE.

Maryland is one of those states that takes its state-authorized hazardous waste program seriously.  Not content to mimic the Federal regulations, it has created state-specific requirements throughout the hazardous waste regulations.  While my Training Seminars are a good way to gain an overview of the regulations and see how your State fits into the picture, it’s Onsite Training where you learn exactly what is required of you by your State Environmental Agency to maintain compliance.  I do both.  Contact me for a free training consultation.

This will be the last in a trio of articles looking closely at the process of determining your hazardous waste generator status. The preceding two were:

• Understanding the Requirements for Determining Your Hazardous Waste Generator Status.
• Determining Hazardous Waste Generator Status Based on Generation of Acute Hazardous Waste.

And now this one:  The Determination of Hazardous Waste Generator Status Based on the Amount of Hazardous Waste Accumulated Onsite.

Keep in mind that this article is meant to assist in determining compliance with the Federal regulations of the US EPA.  Your State, if it has an authorized hazardous waste program, may have its own method for determining hazardous waste generator status that differs greatly from the US EPA.  As always, be sure to check with your State Environmental Agency in order to ensure compliance.

The most common method of determining your hazardous waste generator status is to consider the amount of hazardous waste generated.  However, there are two situations where the amount of hazardous waste accumulated onsite can make a change – in one situation, a drastic change – to your hazardous waste generator status.

We’ll start at the top.  The Large Quantity Generator (LQG) status of hazardous waste generator is based solely on the amount of hazardous waste (≥1,000 kg/mo) or acute hazardous waste (>1 kg/mo or >100 kg/mo spill residue) generated.  An LQG has no upper limit on the amount of hazardous waste or acute hazardous waste it may generate or accumulate.  There is however a limit to how long an LQG may accumulate hazardous waste onsite (≤90 days).

Next is the Small Quantity Generator (SQG) status, which may be determined by the amount of hazardous waste generated (>100 kg/mo but <1,000 kg/mo) or by the amount accumulated onsite.  The accumulation of hazardous waste is a factor if a Conditionally Exempt Small Quantity Generator (CESQG) accumulates ≥1,000 kg of hazardous waste at any one time.  If the threshold of 1,000 kg of hazardous waste is met or exceeded by a CESQG, the hazardous waste immediately becomes subject to all the regulations of an SQG [40 CFR 261.5(g)(2)].

An SQG must also watch the amount of hazardous waste it accumulates.  If at any time a Small Quantity Generator exceeds 6,000 kg of hazardous accumulated onsite the SQG catapults over the LQG status where you might expect it to land and finds itself in the realm of a storage facility “…subject to the requirements of 40 CFR parts 264, 265 and 267, and the permit requirements of 40 CFR part 270…”[§262.34(f)].  The hazard presented by this threshold of 6,000 kg cannot be over-stated.  There can be very stiff fines associated with operating a hazardous waste storage facility without a permit.  For this reason, an SQG must keep a close watch on the amount of hazardous waste accumulated onsite.  An SQG also has an onsite accumulation time limit of no more than 180 days for its hazardous waste.

Conditionally Exempt Small Quantity Generator (CESQG) status, similar to LQG status, is based solely on the amount of hazardous waste (≤100 kg/mo) and acute hazardous waste generated (≤1 kg/mo or ≤100 kg/mo spill residue).  However, as noted above, if a CESQG accumulates onsite at any one time an amount of hazardous waste ≥1,000 kg, then that hazardous waste immediately becomes subject to the regulations applicable to a Small Quantity Generator of hazardous waste.

The big take away from this article is that both SQG’s and CESQG’s must keep a close eye on the amount of hazardous waste they accumulate onsite while monitoring the amount of hazardous waste they generate, and – in the case of the SQG – the length of time the hazardous waste is accumulated onsite.

The determination of your hazardous waste generator status is an important step in maintaining your compliance with the regulations, but it’s not the only one.  Once your status is determine with confidence you must then focus on complying with the regulations applicable to your hazardous waste generator status.  That takes knowledge of the regulations and – depending on your status – may require training.

I provide training required by the US EPA, and your State, for Hazardous Waste Personnel and that required by the US DOT for Hazmat Employees.  Contact me to discuss your training needs.

In the beginning…there was unregulated disposal of waste generated by commercial and industrial facilities, both public and private.  Today there are the hazardous waste regulations written and enforced by the US Environmental Protection Agency and individual states if they have an approved hazardous waste program.  So, what was life like for what we now refer to as the “Regulated Community” before there were regulations?  Pretty simple for them, but not so good for the environment. Get ready for a history of the Resource Conservation and Recovery Act.

A common industry practice in those days was to dispose of hazardous waste onsite by burying, burning, or indefinite storage or have it shipped offsite for something similar.  In either case records were not required nor kept.  Not only did this cause damage to the environment, but the lack of recordkeeping made it impossible for property owners to know what, if any, pollutants were on their property due to past activities.

One cause of this pollution is a flaw in capitalism – a system I love – known as the Tragedy of the Commons.  Basically the cost for damage to the environment caused by a polluter were borne by all instead of just the polluter.  Thus an incentive for polluters to dispose of waste in the cheapest and the least environmentally-friendly manner possible:  open dumping.

Another cause was that the regulation of waste was not thought to be the responsibility of the Federal government and was left to state and local government.  This resulted in an inconsistent patchwork of regulations throughout the country.  The inter-state transportation of hazardous waste, not to mention the ability of pollutants to cross borders on their own, made effective regulation impossible.

A factor that exacerbated the situation was the increase in the volume and toxicity of waste generated starting in the 1960’s.  Note the following statistics from 25 Years of RCRA:  Building on our Past to Protect our Future:

• In the decade between 1950 and 1960, the amount of trash individuals created increased 60 percent.
• In 1965, more than four million chemicals were being produced in the U.S. and synthetic chemical manufacturing
  was on the rise.

By the 1960’s it was clear that something had to change.

This resulted in the 1965 passage of the Solid Waste Disposal Act (SWDA).  The SWDA did not emphasize the regulation of waste throughout its lifecycle, but instead focused on training and research as a means to identify methods to manage waste.  It did, however, set minimum standards for local landfills.  It had little to no effect on generators of hazardous waste.

The SWDA was amended in 1970 by the Resource Recovery Act (RRA).  The RRA emphasized the recovery of energy and materials from solid waste over disposal.  Even with this amendment the regulations were still nothing like we know them today.  For example:  open dumping of waste was not yet banned, companies did not have “Cradle to Grave” responsibility for the hazardous waste they generated, and there was no permit program for hazardous waste generators, transporters, or disposal facilities.

All of that changed in 1976 with the Resource Conservation and Recovery Act (RCRA) which was merely an amendment to the SWDA of 1965, and has been amended itself many times since.  However, due to the sweeping nature of the changes it introduced it remains synonymous with the regulation of hazardous waste in the United States.  With RCRA, for the first time the generation, transportation, and disposal of hazardous waste came fully under Federal regulations (and state regulations if the state was authorized to manage RCRA) and open dumping of waste was to be banned by 1983.

Read the EPA Press Release – December 13, 1976.  Broadly speaking RCRA’s goals were and are:

• To protect human health and the environment from the potential hazards of waste disposal.
• To conserve energy and natural resources.
• To reduce the amount of waste generated.
• To ensure that wastes are managed in an environmentally sound manner.

RCRA is legislation; it is not regulation.  It did however authorize the US EPA (created in 1970) to draft the regulations to realize the goals of RCRA.  Though not the first regulations to come from RCRA, it is the “Hazardous Waste and Consolidated Permit Regulations,” published in the Federal Register on May 19, 1980 (45 FR 33066; May 19, 1980), which established the basic Cradle to Grave approach to hazardous waste management so familiar to all of us today.

“But wait!” You say, “What were the requirements for a hazardous waste generator from December 13, 1976 – when RCRA was signed into law – to May 19, 1980 when the first hazardous waste regulations were published?”  I’m no lawyer, but the best I could determine is that during the period between when RCRA was passed and the regulations were written a generator, TSDF, and/or transporter of hazardous waste need only comply with the regulations in affect at that time:  those created by the the Solid Waste Disposal Act of 1965.  In other words:  “Not much”.  Of course, some states and municipalities had out-paced the US EPA and had their own regulations in place well before the RCRA regulations were codified.  An example of this is the state of California which passed its Hazardous Waste Control Law in 1972.  The HWCL served as a model for RCRA passed four years later and to this day California’s hazardous waste regulations are much more strict and broad than those of the US EPA.

Post-RCRA:

RCRA has been amended many times since its inception, each resulting in a change to the hazardous waste regulations in the CFR.  Some amendments were additions, clarifications, and corrections of typographical errors.  Others resulted in significant changes to the regulations and affected a large number of the regulated industry.  A full description of these amendments will need to wait for a future article.  In brief, however, amendments to RCRA are as follows:

Used Oil Recycling Act of 1980 – Intended to encourage the recycling of Used Oil by exempting if from regulation as a hazardous waste if certain requirements are met.

Solid Waste Disposal Act Amendments of 1980 – Intended to provide US EPA with greater enforcement authority over illegal dumping of hazardous waste.  It also created a category of large-volume wastes thought to be low-toxicity that were excluded from definition as a hazardous waste and would be categorized as Special Waste.

Hazardous and Solid Waste Amendments of 1984 – These 1984 amendments made the most substantial additions to the program by significantly expanding RCRA’s coverage and requirements for hazardous industrial wastes.

Medical Waste Tracking Act of 1988 – In effect for a limited time (expired in 1991) and for a limited area (4 eastern states and Puerto Rico).  The regulation of medical waste is currently the responsibility of the states.

Federal Facility Compliance Act of 1992  – Strengthened enforcement of RCRA at Federal facilities.

Land Disposal Program Flexibility Act of 1996 – provided regulatory flexibility for land disposal of certain wastes.

Read more: http://www.referenceforbusiness.com/encyclopedia/Res-Sec/Resource-Conservation-and-Recovery-Act.html#ixzz2Irh6TYoz

Nothing in this article may cause you to substantially change the way you manage hazardous waste.  However, knowing the history of the regulations can help to form a broad understanding of where we’ve been and – more importantly – where we’re going as a regulated community.  That is why I always include a brief history of US EPA & RCRA in my training.  Whether it’s through legislation, interpretation, or enforcement, RCRA is always changing.  Make sure your training addresses these changes so you can 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.

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.

A very good example of important news being announced in the Federal Register is the very recent announcement of the US DOT’s extension of the authorization for use of the ORM-D classification.

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.  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.

January 2013

Transportation of Hazardous Materials:

• FINAL RULE – Hazardous Materials: Harmonization with International Standards (RRR) Pages 987 – 1100 [FR DOC # 2012-31243]
• FINAL RULE – Hazardous Materials: Harmonization With the United Nations Recommendations on the Transport of Dangerous Goods: Model Regulations, International Maritime Dangerous Goods Code, and the International Civil Aviation Organization Technical Instructions for the Safe Transport of Dangerous Goods by Air Pages 1101 – 1118 [FR DOC # 2012-31242]
• PROPOSED RULE – Hazardous Materials: Transportation of Lithium Batteries Pages 1119 – 1120 [FR DOC # 2012-31244]
• NOTICE – Actions on Special Permit Applications Pages 3965 – 3966 [FR DOC # 2013-00704]
• NOTICE – Notice of Applications for Modification of Special Permit Pages 3966 – 3967 [FR DOC # 2013-00707]
• NOTICE – Notice of Application for Special Permits Pages 3967 – 3968 [FR DOC # 2013-00706]
• NOTICE – Notice of Delays In Processing of Special Permits Applications Pages 3968 – 3968 [FR DOC # 2013-00702]

Management of Hazardous Waste (RCRA)

• PROPOSED RULE – Fall 2012 Regulatory Agenda Pages 1624 – 1631 [FR DOC # 2012-31502]
• NOTICE – Waste Import and Export; Inquiry To Learn Whether Businesses Assert Business Confidentiality Claims Pages 2669 – 2672 [FR DOC # 2013-00575]
• NOTICE – Public Comment on EPA’s National Enforcement Initiatives for Fiscal Years 2014-2016 Pages 5799 – 5800 [FR DOC # 2013-01706]

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 basic requirements of the USEPAs Federal regulations for the accumulation of hazardous waste in a Satellite Accumulation Area [40 CFR 262.34(c)].  Most states with an authorized hazardous waste program incorporate the Federal regulations for SAAs and the State of Missouri is no exception.  It has an authorized hazardous waste program and has largely incorporated by reference the Federal regulations, however, as the Missouri Code of State Regulations reads at 10 CSR 25-5.262:

This rule sets forth standards for generators of hazardous waste, incorporates 40 CFR part 262 by reference, and sets forth additional state standards.

Emphasis mine.

In this article I will explain what is necessary for a generator of hazardous waste in Missouri to manage hazardous waste in a satellite accumulation area in order to comply with the regulations of the MO Department of Natural Resources [10 CSR 25-5.262(2)(C)(3)].

First, let’s review the regulatory requirements where MO DNR and USEPA agree, they include:

• Container(s) must be of good condition and suitable for the safe storage of hazardous waste.
• Container(s) must be properly marked with either the words “Hazardous Waste” or other words that identify the contents of the container.
• Container(s) must be kept securely closed except when waste is added or removed.  Generator must manage the waste in a way that prevents or minimizes the possibility of exposure, spills, fire, loss of vapors, etc.
• Container(s) must be at or near the point of generation of the waste.
• Container(s) must be under the control of the operator.  MO DNR guidance specifies:

 SAA must be located where the process or equipment operator has a clear view of the satellite area at most times when the generating process or equipment is operating.

• SAA may not store more than one kilogram (1 Kg) of acute hazardous waste.
• No limit on the different types of hazardous waste or number of containers in an SAA.  See below for an explanation of how Missouri expands on this limit.
• The weekly inspection requirements of hazardous waste containers at Large Quantity Generators or Small Quantity Generators of hazardous waste (determine your hazardous waste generator status) do not apply in SAAs (read this article to learn about USEPA regulations for weekly inspections in SAAs).  However, it is a good idea to conduct periodic inspections of these areas.

Now let’s take a look where Missouri differs from the Federal regulations:

• Hazardous waste may not accumulate in an SAA for more than one year.  The one year time limit for accumulation in an SAA begins at the moment the first drop of hazardous waste enters the container in the SAA.  This differs greatly from the USEPA which has no limit on the amount of time a hazardous waste may accumulate in an SAA.
• Due to the above Missouri facilities have an additional marking requirement:  The date of accumulation must be marked clearly on the container.  In other words, the date the first drop of hazardous waste is added must be written on the container.
• You may accumulate more than 55 gallons of hazardous waste in an SAA provided you have no more than one 55-gallon container per wastestream in each SAA.  This differs greatly from the USEPA which allows no more than 55-gallons total volume of hazardous waste in each SAA.  Compliance with this requirement is made more difficult by the fact that you will not find any mention of it in the Missouri regulations.  In a recent conversation with the MO DNR I was told that this expansion on the Federal regulations is based on an interpretation by the MO DNR and how it chooses to enforce its regulations.  You will find a reference to this allowance in an MO DNR guidance document I have a link to at the end of this article.
• Once any single container is full (whether it is a 55-gallon container or smaller) it must be marked with the date the container became full, and marked, labeled and otherwise  managed according to the Missouri regulations for generator storage of hazardous waste.  Further, the container must be shipped off-site for final treatment, storage, or disposal or moved to the facility’s Central Accumulation Area for storage of hazardous waste within 3 calendar days of being full.  If moved to the facility’s CAA, it may be dated again and stored onsite for another 90, 180, or 270 days as applicable.
• Under no conditions may a hazardous waste (acute or non-acute) remain in an SAA for longer than one year from the first moment hazardous waste is added to the container.
• MO DNR requires that personnel who are exposed to hazardous waste in an SAA receive training to ensure they are familiar with proper management procedures, health and safety risks, and procedures in the event of an emergency.  This is another departure from the Federal regulations which have no training requirement for personnel exposed to hazardous waste in an SAA.  Also, you won’t find this requirement in the regulations or the MO DNR guidance document.  However, I was told in recent conversation with the MO DNR that they do expect you to provide this training.

Example:

A Missouri facility manages three 55-gallon and one 5-gallon container of hazardous waste in a single SAA; each container has a different kind of non-acute hazardous waste.

• The facility may continue to manage all of the hazardous waste in the SAA provided all of the applicable regulatory requirements are met.
• If any one of the containers becomes full within one year of the start of hazardous waste accumulation the container should be closed, dated, and managed according to the MO DNR regulations for hazardous waste storage.  The facility has three calendar days to ship offsite or move to its CAA.
• If any container has remained in the SAA for one year from its date of initial accumulation (1st drop!) the container must be immediately removed from the SAA to the CAA or shipped offsite to a TSD Facility.

Conclusion:

Staying on top of the Federal hazardous waste regulations of the USEPA can be a challenge.  You must also be aware of those of your state, especially where it differs from the Feds; and especially if, like Missouri, your state has gone well beyond the USEPA in its regulations, interpretations, and enforcement.

If you have any doubts about your facility’s compliance with these regulations I encourage you to contact the MO DNR for a site-specific assessment of your operations.  Also, here’s that MO DNR guidance document I mentioned earlier:  MO DNR Hazardous Waste Satellite Accumulation.

I encourage you to attend my training to brush up on the Federal regulations and gain a perspective on those of your state.

And hey!  I’ll be in Kansas City, MO on June 5th, 2014 for one solid day of training:  4 hours of Hazardous Waste Personnel (USEPA) and 4 hours of HazMat Employee (USDOT).

US EPA News Release:

PHILADELPHIA (Jan. 22, 2013) — Phillips 66 Company has agreed to pay a $50,000 penalty to settle alleged violations of hazardous waste regulations at its former refinery located in Trainer, Pa., the U.S. Environmental Protection Agency announced today.

Phillips 66 Company is the successor to ConocoPhillips Corporation, which owned the refinery at 4104 Post Rd., Trainer, Pa. The facility was sold to Monroe Energy, a subsidiary of Delta Airlines in 2012.

EPA cited the company for violating the Resource Conservation and Recovery Act (RCRA), the federal law governing the treatment, storage, and disposal of hazardous waste. RCRA is designed to protect public health and the environment, and avoid costly cleanups, by requiring the safe, environmentally sound storage and disposal of hazardous waste.

Following two inspections in 2011 and 2012 by EPA and subsequent requests for information, EPA cited Phillips 66 for RCRA violations involving hazardous waste stored at the facility, including oil refinery hydrocarbon waste, chromium waste, heavy metal waste from batteries, and mercury waste from fluorescent bulbs.

The alleged violations included operating a hazardous waste treatment, storage or disposal facility without a permit, failure to keep several hazardous waste containers closed except when necessary to add or remove waste, failure to update the company’s contingency plan following a change in emergency coordinators, failure to maintain hazardous waste management personnel designations and job descriptions, and failure to properly manage universal waste batteries and waste lamps.

The settlement penalty reflects the company’s compliance efforts, and its cooperation with EPA in the resolution of this matter. As part of the settlement, Phillips 66 Company has neither admitted nor denied liability for the alleged violations.

For more information about hazardous waste and RCRA, visit http://www.epa.gov/epawaste/hazard/index.htm.