The Bullet:
A Dover, DE store in the Royal Farms chain was issued a violation by the Delaware Department of Natural Resources and Environmental Control for a simple – but common – violation of the State’s hazardous waste regulations.
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Who:
Royal Farms Store #139 of the Royal Farms chain of retail stores.
Delaware Department of Natural Resources and Environmental Control (DNREC). DNREC Contact: William Davis
What:
As a generator of a solid waste, the store failed in its responsibility under both Federal and State regulations to conduct, and document, a hazardous waste determination.
Where:
Royal Farms Store #139 6 West Lebanon Road Dover, DE 19901When:
Date Discovered: 05/02/2014
Enforcement Action Served Date: 07/22/2014
Date Corrected: 08/21/2014
Why:
A person that discards any material generates a solid waste. Unless that person is exempt from regulation under the Resource Conservation and Recovery Act (RCRA) – and this store clearly is not – they must conduct a hazardous waste determination. This determination must be documented (no format is specified) and a record kept for at least three years from the last date the waste was shipped off-site for treatment, disposal, or recycling.
How:
The state of Delaware – like most other states – has an authorized hazardous waste program which requires it to enforce the RCRA regulations within its borders. A state that does not enforce its regulations stands to loose its authorization to manage its own hazardous waste program.
Conclusion:
A person can be forgiven of thinking that the hazardous waste regulations of RCRA apply only to large industries, utilities, landfills, and the like. It can be surprising to learn that a local retail store is subject to the same regulations. First and foremost among the RCRA regulations is to conduct a hazardous waste determination. From that, a solid waste generator can determine what status of hazardous waste generator they are, and what regulations apply to the cradle-to-grave management of their hazardous waste.
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